DOE~A-0978 .
Sludge Stabil:zation at the Plutonium Finish: ng Plant, -, Hanford Site, Mchland, Washington
U.S. Dep-ent of Energ NcMand, Wash@on
October 1994 _—_—
DOE~A-0978
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U,S. Deparment of Energy Glossary
Glossary
Acronp md Abbreviation
ARF airborne release fraction ASIL Acceptable Source Impact Level D&D dmontamination and decommissioning DOE U.S. Department of Energy EA Environment Assessment Ecology State of Washington Department of Ecology EDE effective dose equivalent EIS Environment Impact Statement EPA U.S. Environment Protection Agency FFTF Fmt Flux Test Facflity HEPA High-Efficiency Partictiate Air LFL lower flammability limit LCF latent cancer fatrdity NESHAP Natioti Emission S~dards for H=dous Air Pollutants PFP Plutonium Finishing Plant PRF Plutonium Reclamation Factiity PUREX Plutonium-Uranium Extraction RCW Resource Conservationand Recove~ A~ of 1976 rem Roentgen Equivalent Man RMC ~ remote mechanical “C” TBP tributyl phosphate TLV-STEL Threshold Limit Value - Short Term Exposure Limit TLV-TWA Threshold Limit Value - Time Weighted Average Tri-Party Agreement Hanford Federal Facilip Agreement and Consent Order TRUS@ Transuranic Waste Storage and Assay Factiity WAC WmhingtonAdministr~.ve Code WIPP Waste Isolation Ptiot Plant
Definition of Selected Tem
Effective Dose Eauivdent. A value used for estimating the toti risk of potential health effects from radiation exposure. This estimate is the sum of the committed effective dose equivalent from interti deposition of radionuclidm in the body and the effective dose equivalent from exterti radiation received during a year.
Latent cancer fatalitv: The excess mcer fatiities h a population due to exposure to a carcinogen.
DOEEA-0978 October 1994
— -—— — U.S. Department of Energy Glossary
Defiition of Seleded Terms (cont.)
Maximdlv exuosed individud. A hypothetical member of tie public residing near the Hanford Site who, by virtue of location and living habits, could receive the highest possible radiation dose from radioactive effluents released from the Hanford Site.
Person-rem. A population dose based on the number of persons multiplied by the radiation dose.
Plutonium Finishing Plant. The Plutonium Finishing Plant, a complex of many butidings, mostiy atiched, that functioned to provide plutonium in various forms for defense purposes. In the past, the plant has dso been referred to as the “Z Plant. ”
roent~en eauivdent man (rem). A special unit of dose equivalent that indicates the potential for impact on human cells.The dose equivalent in reins is numericrdly equal to the absorbed dose in rads multiplied by the quality factor, the distribution factor, and any other necessary modifying factors.
Remote mechanical “C”. Remote mechanical “C” line, historically the third planned meti processing line at the Plutonium Ftishing Plant.
x. A muddY Or SIUShYm~s, deposit, Or sedfient SUCh= a PreciPi~ted solid matter or a precipitate or setiing in liquid (such as a mixture of impurities and acid).
Transuranic waste. Without regard to source or form, radioactive waste that at the end of institutioti control periods is con-ted with alpha-emitting radionuclides of atomic numbers greater than 92 with hrdf-lives greater than 20 years and concentrations greater than 100 nCi/g.
Scientific Notation Conversion Chart
Mdtipfier I Eqnivdent Mdtipfier Equivalent 10’ I 1,000,000 ~ol 0.1 10’ / 100,000 102 .01
104 I 10,000 103 .001 103 I 1,000 II 104 I .0001
lV I 100 II 10’ I .OOOO1 ’101 I 10 II lo~ I .000001 loo 11 II 10-7 I .0000001 I II 108 I .00000001
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DOE~A-0978 G-2 October 1994
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U.S. Department of Energy Glossary
( Metric Conversion Chart
Mdtiply n you how To get E you how MdtipIy by To get by
Length
centimeters 0.393 inches Mometers 0.62 ties
meters 3.2808 feet cubic meters 35.34 cubic feet
Area
square 0.39 square ties square 0.1550003 square kilometers centimeters inch
Mass (wei@t)
grams 0.0022 pounds grams 0.035 ounces
Mlograrns 2.2046 pounds
Volume
liters 0.26 gtions cubic meters 35.3147 cubic feet
Temperature
Celsius mdtiply by 9/5ths, then add 32 Fahrenheit
I Source: ~C Ha@ook of Oem ad P@tia, Robert C. W-t, Ph.D., 70th Ed., 1989-1990, CRC Press, he., Boca Raton, Morida.
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DOE~A-0978 G-3 October 1994 ,- . ... . I U.S. Depwtient of Energy Executive -W I I Executive S~ary
‘1I This Environment Assessment evaluates the proposed action to operate two
laboratory-size muffle furnaces in glovebox HC-21C, lomted in the Plutonium Finishing I Plant (PFP), Hanford Site, Rictiand, Washington. A muffle furnace is a type of small electric radiant oven. The cavity is surrounded by fue brick to separate the material being
dried from the heating elements. The muffle furnaces would be used to stabflize chemically
reactive sludges that contain approximately 25 tiograms (55 pounds) of plutonium by
1 heating to approximately 500 to 1000 ‘C (900 to 1800 ‘F). The resulting stable powder, 1I mostly plutonium oxide with impurities, would be stored in the PFP vad~. I
The presence of chemic~y reactive plutonium-bearing sludges in the process
gloveboxes poses a risk to workers from radiation exposure and limib the avaflabtiity of
storage space for future plant cleanup. Therefore, there is a need to stabflizethe material . into a form suitable for long-term storage. This proposed action would be an interim action,
which would tie place prior to completion of an Environment Impact Statement for the
PFP which would evaluate stabdization of dl plutonium-bearing materials and cleanout of the
factiity. However, ody 10 percent of the toti quantity of plutonium in reactive materials is
in the sludges, so this action wtil not limit the choice of reasonable alternatives or prejudice
the Record of Decision of the Plutonium Finishing Plant Environment Impact Statement.
The sludge stabdization process would consist of relocating sludge containers from the
Plutonium Reclamation Facflity to Room 230A and into glovebox HC-21C, pouring the
material into a boat (crucible) for heating, and weighing tie fu~ boat. After weighing the
DOE~A-0978 m-l October 1994 -.. U.S. Depar~ent of Energy Executive Sununary boat, it would be placed into one of the tinaces, and the furnace temperature controller would be programmed to slowly heat the sludges. The heating cycle would vary depending on the composition of the sludges. During the heating process, plutonium compounds would be converted to plutonium oxide, and any excess moisture would be driven off. After heating, the furnace would be allowed to cool, then the stabtiized material would be removed from the furnace, transferred to another glovebox, sieved, and dyzed for stabtiity. Other routine operations may be performed on the material, such as hand grinding the residues in order to prepare the material for storage. If acceptable, the material would be repackaged and removed from the glovebox for storage. Material that does not meet storage acceptance criteria would be recycled through the stabflintion process.
Completion of sludge stabtiization would require about 400 to 600 batches. The uncertainty is due to the assumed recycle rate and other factors. It is estimated that the process would average two batches, per furnace, per day. Each batch would be limited to less than 500 grams (1. 1 pounds) of material per batch, and less than 2 percent organic composition. The stable, impure plutonium oxide would be packaged in approximately 150 l-liter (0.264-gdlon) containers, and stored in the PFP storage vaults awaiting future disposition. There is sufficient capacity in the vaults to accept this material.
The No-Action alternative to the proposed action would be to not process the sludges.
The sludges would continue to be stored in the gloveboxes. This would not accomplish the I purpose for this proposed action.
DOE~A-0978 Es-2 October 1994 I -- —., 1 ,:’. ,, . .—.. —
U.S. Depmment of Energy Executive -SY
Another alternative to the proposed action would be to discard the sludges as waste,
rdthough this alternative is not permitted under current rules. The sludges would be
combined with a cement-like material which would be packaged in waste drums.
Approximately 250 208-liter (55 gallon) drums of contact-handed transuranic waste would be i generated from the sludges. The drums would be stored in Hanford Site waste facfiities,
untfl a fii repository was avaflable.
Another alternative considered several processing alternatives that would stabflize the
sludges. These processing operations include operating the Plutonium Reclamation Facflity
(PRF) or vitrifying the sludges. These alternatives are viable; however, tie PRF process is
simtiar to historical defense production proctises; in some instances (i.e., vitri@ing), make
the processed material incompatible for future disposition and would expose the operating
staff to substantially higher doses of radiation.
Operation of the furnaces under the proposed action would produce low levels of
radiological air emissions due to the furnace offgas. The offgas would be faltered twice prior
I to exiting the plant stack. After passing through the fdtration, the to~ plant emissions
would not be measurably increased above current levels. The estimated health effect to the
public from toti plant emissions has historically averaged about 0.00005 latent cancer
fatality (LCF) per year (O.1 Roentgen Equivalent Man [rem] per year) for the population
within 80 Uometers (50 mfles) of the PFP. No fati mcers are expected to be attributable
to this exposure.
DOEkA-0978 Es-3 October 1994 U.S. Depa~ent of Energy Executive SununWy
The process would generate small amounts of gaseous butene, nitrogen oxides, carbon
dioxide and water. The resulting maximum onsite and offsite concentrations from continuous
emission of these chemicals out the plant stack would be a factor of 1~ or lower than any
applicable health standards.
Approximately 0.01 cubic meters (0.5 cubic feet) of solid waste, per day, would be
generated from disposd of storage containers and normal operational waste such as glovebox
sedouts and lab analyses.
Workers w~uld be exposed to radiation when they perform stabilization operations in
proximity to the sludges at a composite rate of about 10 mtilirem per hour. The process is
expected to require about one hour each of close proximity work per shift for three workers,
which would result in a cumulative dose of 17 person-rem for the stibtiization operation.
This dose could result in an estimated health effect of 0.007 LCF (17 rem) for the workers
as a result of the stabilization operation. No fati cancers are expected to be attributable to
this exposure. No physical impact would result outside the plant from the postulated
accident.
The bounding accident postulated for this operation was determined to be a flammable
gas @utene) deflagration inside the glovebox, which breaches the glovebox, and disperses
126 grams (0.28 pounds) of plutonium into the room. The probabtiity for this accident is
estimated to be less than 0.00001 occurrences per year. This postulated accident could result
in 0.048 grams (0.001 pounds) of plutonium relemed from the plant stick which would have 1 a herdth effect of 0.0015 LCF (3.75 rem) to the 140 exposed onsite population and
DOE~A-0978 ES* October 1994 I ,——_....— 1 ..._ .—.-~. . . ,.,’ .,. ;..-rt .- .!.: ,.. U.S. Depmtient of Energy Executive -NY
0.011 LCF (22 rem) to tie 114,734 exposed offsite population. No offsite or onsite
population fati cancers are expected to be attributable to tiis exposwe. ,
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DOEEA-0978 W-5 October 1994 .- .———.
U.S. Depar~ent of Energy Table of Contenk
Table of Contents
l. OPurpose and Need for Agency Action ...... 1-1 l.l Background ...... 1-1
2.0 Description oftie Proposed Action ...... J ...... 2-l 2.1 Sludge Stibfli=tion ...... 2-1 2.2 Process Description ...... 2-1 2.3 Facfiity Description ...... 2-4 2.3.1 Plutonium Finishing Plant...... 2-4 2.3.2 Room230A and Room230B ...... 2-5 2.3.3 Glovebox HC-21C ...... 2-6 . 3.OMternatives tothe Proposed Action ...... 3-1 3.1 No-Action Mternative ...... 3-1 3.2 Disposal Aternative ...... 3-1 3.3 Processing Aternative ...... 3-2 3.4 Offsite Treatment and Storage of Sludges Mternative ...... 3-2
4. O Affected Environment ...... 4-1 4.1 Plutonium Finishing Plant Complex ...... 4-1 4.2 hcation and Regioti Population ...... 4-1 4.2.1 Regioti and Site Activities ...... 4-1 4.2.2 Physid Environment ...... 4-1 4.3 Culture Resources ...... 4-3
5.OEnvironmenti Impacts ...... 5-1 5.1 Air Emissions ...... 5-1 5.1.1 Radionuclide Air Emissions ...... 5-1 5.1.2 Chemical Air Emissions ...... 5-2 5.2 Worker Radiation Exposure ...... 5-3 5.3 Solid Waste ...... 5-4 5.4 Accident Potentia l ...... 5-4 5.4.1 Accident Scenario ...... 5-4 5.4.2 Probabtiity ...... 5-5 5.4.3 Sourw Term ...... 5-6 5.4.4 Accident Consequences ...... 5-6 5.5 Socioeconomic Impacts ...... 5-7 5.6 Cumulative Impacts ...... 5-7 5.6.1 Cumulative Impacts - Air @dioactive) ...... 5-7 5.6.2 Cumulative Impacts - Solid Waste ...... 5-8
6.0 Permits and Regulatory Requiremen@ ...... 6-1 6.1 Air Qualit y ...... 6-1 6.2 Solid Wastes ...... 6-1 6.3 Hanford Federd Facflity Agreement and Consent Order ...... 6-1
DOE~A-0978 TC-1 October 1994
— U.S. Department of Energy Table of Contents
7.0 Agencies ...... O 7-1
8.0 References ...... 8-1
MPE~ICES
A. Finishing Plant Radionuclide Air Emissions Data . . . . . A-1
B. Chemical Air Emissions Data...... B-1
c. Cultural Review ...... c-1
D. Tribdand Stieholder Involvement ...... D-1
E. Review ...... E-1
l. Hanford Site ...... F-1
2. 200 West Area ...... F-2
3. Remote Mechanical “C” Line bcation Within the Plutonium Finishing Plant Complex ...... F-3
4. Plot Plan for Rooms 230Aand230B ...... F-4
LET OF TMLES
Plutonium Reclamation Facfiity Sludge Composition ...... :. 2-2 Remote Mechanical “C” Line Plutonium Oxycarbonate Composition ...... 2-2 Annual Plutonium FWhing Plant Collective Dose and Health Effect ...... 5-2 Chemical Concentrations at the Maximum Onsite Receptor bcations Based on 99.5 Percent Meteorology and Comparison to TLV-~A and TLV-STEL Limik. .5-3 Chemical Concentrations at the Maximum Offsite Receptor Locations Based on Annual Average Meteorology and Comparison to ASIL Values...... 5-3 Health Effects from Accident Scenario...... 5-6
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October 1994 I DOE~A-0978 TC-2 I
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U.S. Dep~tient of Energy @ose ad Need for Agency Action
1.0 Purpose and Need for Agency Action
The DOE needs to reduce worker exposure to radiation at the PFP. Currenfly, the PFP workers account for nearly hdf of dl Hanford Site radiation exposure. One of the largest sources of worker exposure in the plant that can be decreased is the constant need for proximity to unshielded gloveboxes containing sludges in order to monitor the conditions of sludge containers, to inventory material, and to perform routine housekeeping and preventative maintenance operations. Radioactive decay products (matiy americium-241) butid up in stored plutonium. These decay products in the sludges cause increased worker radiation doses. This dose can be reduced incremen~y as the sludges are stabtiized and moved to vault storage.
The DOE dso needs to increase avaflable shielded glovebox storage space for reactive residues. Sludges occupy the majority of the shielded glovebox space, which would be required for future actions to cleanup plutonium-contaminated portions of the plant. Planned future cleanup activities include cleanout of ventilation ducts, falter boxes, access bays, and other areas of the PFP.
In the past, the Plutonium Finishing Plant @FP) was used to process plutonium-based chemicals to produce pure plutonium meti or oxide. The U.S. Department of Energy (DOE) then shipped these products offsite to be used b the nation’s weapons program. The last production operations were conducted in 1989. Reactive scrap materials remain in the process areas of the facflity, including plutonium-bearing sludges, process solutions, and other materials.
1.1 Background I ! The PFP began operations in 1949 to convert plutonium titrate solutions into plutonium t I metal. This activity continued in various campaigns through 1988. A a result of the ,! { conversion process, a number of scrap forms of material were generated, some of which t could not be immediately recycled into the process and thus required storage. The shielded and secure vaul~ were designed to store these materials h sealed storage containers located in Building 2736-Z (Figure F-3). Sealed storage requires the removal of any gas-fortig compounds. If such compounds are not removed, sufficient gas to pressurize individud ‘, storage containers can be evolved leading to their rupture and a release of plutonium into the vaults. The gas is generated primarfly from chemictiy active compounds and the radiolysis of hydrogen-bearing compounds. HistoricWy, such compounds have been processed (i.e., “stibtiized”) by heating them in a small furnace to high temperatures. This effectively drove off water and decomposed organic or other molecules to gaseous forms. The resulting residues were canned to serd out moisture and contain the plutonium.
Stabilization operations were halted in 1989 due to concerns about ignition of flammable gas generated in the stabtiization procms after many years of uneventful processing. If a sufficient quantity of flammable gas had been generated and ignited, the glovebox could be breached and plutotium could be released into the surrounding room (i.e., room 235C).
DOE~A4978 1-1 October 1994 I U.S. Department of Energy @ose and Need for Agency Action
To reduce the likelihood of a flammable gas deflagration and to mitigate any attendant consequences, new finaces with improved flammable gas control have been instiled in glovebox HC-21C. Glovebox HC-21C is located in room 230A. This room, as well as adjoining rooms and corridors, is serviced by a ventilation system equipped with High-Efficiency Particulate Air (HEPA) fiiters. Should procws safety features be compromised, these falters would remove, at a minimum, 99.95 percent of the plutonium entrained in the air.
The proposed action includes operation of two laboratory-scale muffle furnaces (electric radiant ovens) in a glovebox. 1 Minor modifications WMbe made to piping inside the glovebox and h room 230A. Piping modifications include running a carbon dioxide (COZ) gas purge to each furnace and running an offgas removal line from each furnace. A control console wfll be instiled in room 230A for furnace temperature readouts and controls.
Stabilizing the sludges would allow the materials to be stored in well-shielded vaults where they would be remotely monitored and would require less handing during inventory. It is estimated that this would reduce worker exposure for dl PFP operators by 4 rem per year. This would result in less worker exposure and less risk of accidenti contamination.
In July 1993 an EA was initiated to review operation of the major PFP processes to stabflize most df these sludges along with process solutions and other scrap materials. However, DOE decided to increase the level of National EnvironmentalPoliq Act of 1969 review to that of an Environment Impact Statement (EIS). The scope was expanded to review reasonable alternatives for the stibfiization of dl plutonium bearing materials, cleanout of the PFP factiities (except for storage) to a state ready for decontamination and decommissioning (D&D), and/or potential fiture uses. Publication of the Notice of Intent is expected on October 27, 1994.
This action to stibflize the sludges in the gloveboxes would be an interim action pending completion of the PFP EIS dysis and Record of Decision concerning the proposed cleanout of the PFP and stibflization of the remaining materials within the PFP. This need is being addressed now because the sludges now in unshielded gloveboxes are a large source risk of worker exposure due to the need for cons~t handling, which may be easfly reduced. Additiondly, the sludges dso occupy the majority of the shielded glovebox space required for any fiture actions to cleanup plutonium con~inated portions of the plant. However, only 10 percent of tie toti quantity of plutonium in reactive materials at the PFP is in the sludges, so this action WMnot limit the choice of reasomble alternatives or prejudice the Record of Decision.
I1 1Amuffle hce uses a barrier to separate a batch of materi~ from the h=ting elements. h principle, the I furnace operates stiarly to a pi- oven. 1 I DOE~A-0978 1-2 October 1994 I _.— -..-—- — -— ———-,-— I .“:,-. , .,. -- -,.~~ ,, U.S. Department of Energy Description of the Proposed Action
2.0 Description of the Proposed Action
The proposed action would be to stabtiize the chemically reactive plutonium-bearing sludges within both unshielded and shielded gloveboxes in the PFP. These sludges are residues remaining from previous production processing operations at the PFP. These sludges contain approximately 25 tiograms (55 pounds) of plutonium along with other chemicals in a slurry with high moisture content. me toti quantity of plutonium in the sludges is approxtiately 10 percent of the toti quantity of plutonium in dl the reactive materials stored at the PFP. The remaining 90 percent of the reactive materials in the plant is primarfly in residud process solutions; stabilizing th~e solutions is not within the scope of this Environment Assessment (EA).
Specifically, the proposed action would consist of tie following activities.
2.1 Sludge Stabilkation I I The DOE proposes to stabfiize certain plutonium-bearing sludges by heating the sludges I to approximately 500 to 1000°C (900 to 1800°F), which WU convert the plutonium in the sludges to stable plutonium oxide @uOz). The other chemicals not driven off by the heat would remain as stable impurities in the resulting solid. This solid could be stored in a sealed container in the vaults at the PFP. The reactive scrap sludges wfll occupy approximately 300 containers which require stabtiizatioq these contain a toti of about 25 tilograms (55 pounds) of plutonium. b The process would use two 4000-watt laboratory-size muffle timces instiled in glovebox HC-21C located in room 230A of butiding 234-5Z within the PFP. This stabilization process has been operated in the past at the PFP using an older furnace design in glovebox HA-211 in room 235C.
2.2 Process Description
‘{ The feed materials for sludge stabilization would consist of sludges from the last Plutonium Reclamation Facflity @RF) campaign, the PRF tratig run, ad miscellaneous glovebox floor sweepings from the WC line, consisting primarily of plutonium oxdate that has transformed to plutonium oxycarbonate2 and parttiy converted plutonium oxide. The composition of PRF sludges is presented in Table 1. The composition of the WC line plutonium oxycarbonate is presented in Table 2.
2 Plutonium otiate @(~Oq)J degrades to plutonium oxywbo’mte @OCOj”2HzO) with a reaction hdf-~ie of 64 days. Given that the NC fine sweepings have been in storage in excess of 4 years, essenti~y dl of the plutonium otiate has degraded to the oxycarbomte form. Whereas the heating of otiate in the absence of oxygen generates carbon monoxide (a fl~ble gas), heating of oxy=bomte generates pfitiy less h=dous wbon dioxide and water.
DOEEA-0978 2-1 October 1994 U.S. Depar~ent of ~ergy Description of tie Proposed Action
Table 1. Plutonium Reclamation Fa~ty Sludge Composition.
Compound WeightPereent
M1n I Max Ave Fq03 andFe@O,), o 50 33
ccl, o 1 0 TributylPhosphate 1012111
~wo3)4 o 39 26 PU02 o 10 7.
3-5M mo,-go I o I 50 I 33
Table 2. Remote Medanid “C” Line Plutonium Oxywbonate Composition.
Compound WeightPereent I
~o I 4.4
The sludges would be relocated from their various current storage locations (unshielded Pm and RMC gloveboxes, the Pm canyon, and the shielded HA-23S storage glovebox). This would require movements in and out of gloveboxes. Material would be packaged and sealed out of gloveboxes. Sealing is a routine operation to safely place material in or out of a glovebox in a manner that prevents any exterti contamination from radioactive material. Specifically, material is removed from tie glovebox through a tubular plastic bag which is then sealed in a manner stiar to that of a home food sealer. Material would be sealed in and out of glovebox HC-21A, which is connected to HC-21C, during stabtiization. After the stabtiization process, the impure plutonium oxide would be placed in appropriate vault containers, transported and stored in an existing storage vault for future disposition. There is sufficient capacity in tie vaults to accept this material. During vault storage the containers would be remotely monitored to detect any changes such as container bulging. The vaults are shielded to minimize worker exposure. The material would be periodically inspected and I inventoried to verify its safe condition. I I The stibflization proctis would take place in glovebox HC-21C. Some ancdlary I routine operations, such as sieving, grinding, and sealing in and out, may take place in t glovebox HC-21A which is connected to HC-21C via a conveyor. The plutonium-bearing I
I 3Assues conversion of W otiate to oxywbonate. I
;. DOE~A-0978 2-2 October 1994 1 U.S. Depmtient of Energy Description of tie Proposed Action
sludges would be unpackaged and crushed if necessary. The waste packaging would be sealed out of the glovebox and disposed. The sludges would be poured into flat, low-volume boats (crucibles) for heating. The boats are designed to hold roug~y 1,000 grams (2.2 pounds) of sludge but the charge would be limited to 500 grams (1.1 pounds). The extra volume would be provided to reduce the chance of spdlage during procmsing and handling. . The gross weight of the material and boat would be recorded. The boat would then be placed into one of the furnaces. The ventilation air flow would be started. If the material could potentially contain tributyl phosphate ~P) or its degradation produck, a flow of inert cover gas, such as carbon dioxide, would be introduced into the furnace. The inert cover gas would reduce the potential for ignition of any gaseous produck generated. After the material has reached approximately 300°C (572°F) and any potentially combustible gaseous products have been driven off, the flow of inert cover gas would be stopped, to allow the material to stabtiize.
The temperature controller would be programmed for the material to be processed. The temperature controller regulates the heating cycle, which involves raising and maintaining of the furnace temperature for a spectilc period of time. The furnaces would heat up slowly to about 180°C (356°F) to drive off combustible gaseous products. The material would then be raised to higher temperatures and held there for a period of time to stabilize the material (For example, 760°C [1400°F] for 2 hours). Specific heating regimes would be dependent on the composition of the material being processed. For example, a different cycle would be used for NC glovebox floor sweepkgs than for Pm sludges.
As the sludges are heated, water vapor, carbon dioxide, butene and nitrogen oxide compounds would be relwed in gaseous form through the glovebox venttiation system. The butene would result from d~omposition of the organic compounds, primarfly tributyl phosphate. The nitrogen oxide compounds result horn decomposition of nitric acid and plutonium nitrate. The rema~g product would be a stable, dry, impure plutonium oxide powder.
After the heating cycle is completed, the finace would be allowed to cool. Afier cooling, the material would be removed from the furnace, weighed, sieved and broken up (if necessary), and sampled for stabtiity. The material would be sampled to determine if any moisture remains or has been absorbed into the dried material. The larger pieces that do not go through the sieve would be crushed if necessary and recycled through the furnace. Material which does not meet vault storage stabflity requirements would dso be recycled through the process. If the material mees acceptabtiity criteria it wodd be repackaged and removed from the glovebox and placed in the PFP vaulh.
The second furnace would be operated using the same process. The two furnaces may be operated concurrently or in alternating cycles.
The sludges to be stibtiized would occupy approximately 300 containers (venttiated hdf liter [1 pint] polyjars). Each batch wotid be limited to 500 grams (1. 1 pounds), which wtil
● DOE/EA-0978 2-3 October 1994 — U.S. Department of Energy Description of the Proposed Action
require splitting of full polyjars into two batches.4 The polyjars would contain varying amounfi of sludge, and some @erhaps 20 percent) material may have to be recycled through the furnace. Based on time factors an estimated 400 to 600 batches would need to be processed to complete stibtiization of the sludges. The process is expected to average one to two batches per furnace per day.
The feed would dso be limited to material with less than 2 percent organic composition, primarfiy tributyl phosphate. During the stibfitition process, decomposition of the tributyl phosphate generates butene gas. Other gases generated by the process include nitrogen oxides @Ox), carbon dioxide and water. Each contier of sludge proposed for processhg wfll be tested before stabdtition; ody those contitig less than 2 percent organics wfil be stibflized.
2.3 FaciIi@ Description
2.3.1 Plutotiurn Mhg Phmt
The PFP is located in the 200 West Area of the Hanford Site (Figures 1 and 2). Sludge stabilization operations wotid be conducted in glovebox HC-21C located in room 230A of the 234-52 Buflding. The 234-52 Butiding is the largest of several buildings comprising the PFP.
Several PFP uttiities and services would support sludge stabtiization operations. The most important of these are the E-3 and E-4 venttiation systems and the fiie protection system.
Al buddings served by the PFP ventilation system are zoned to ensure confinement of radioactive materials. Within Butiding 234-52, Zone 1 is designated as those areas where plutonium contamination would not normdy be pr~ent. Zone 3 (there is no Zone 2) consists of areas in which plutonium is stored or handed in contied form, and where there is potential for contiination to occur. Zone 4 consists of the inside of hoods, gloveboxes, and process cells, directiy exposed to plutonium, and which may be grossly contiinated. Differential pressures are maintained between zones to ensure that airflow is from areas of lowest to highest contamination potential.
The air from Zone 3 rooms and corridors (including room 230A and adjacent corridor) is faltered through a single stige of testable HEPA falters located in seven falter rooms, any three of which maybe in normal service and the remainder in stidby. The exhaust air from the falter rooms (approximately 4,560 m3/min [161,000 ti/min]) flows into an exhaust plenum and is discharged to atmosphere via the 61-meter (200-foot) Ml 291-Z-1 stack.
Exhaust from Zone 4 areas (including gloveboxes HC-21C and HC-21A and the vacuum system) is routed to a single stige of testible HEPA fdtration with individud filters,
!
4Plutoniumis much denser than water (500 gr- has a volume of appro~tely one quarter of a liter). I
DOE~A-0978 24 October 1994 I ~ ..— — ,,. ——— —— I ~> ‘,. . 1.
U.S. Depament of Energy Dwctiption of tie Proposed Action
or several falters operated in par~el, located on the duct level (or second floor) of tie 234-52 Butiding. Exhaust from these fiiters is routed to the E-4 falter rooms that provide a second stage of testable HEPA fdtration. The E-4 venttiation exhaust is combined with the E-3 exhaust downstream of the fflters and discharged to atmosphere via the 291-Z-1 stack. The E-4 system exhaust flow is approximately 1,048 m3/rnin (37,000 fi/min).
The PFP fire protection system consists of many individud communication and operating systems that inform or provide action in regard to f~es and fue fighting. The system includes:
I . Fire rdarm systems, which notify the f~e department
I . Heat or products of combustion detector systems that activate an alarm and/or activate a water, dry chemical, or hdon f~e suppression system (the WC gloveboxes is tie ody area where hdon is used).
. Fire barriers to isolate parts of bufldings, thus slowing progress of f~e and reducing damage. Such barriers are dso viti to life safety.
1. ,’ 2.3.2 Room 230A and Room 230B
Glovebox HC-21C is located in room 230A; one of a series of rooms in zone 3 that are located in an interior concrete shell that houses the remote mechanical “C” WC) line of processing gloveboxes @igure 3). Room 230A is 7.9 meters (26 feet) north to south, 6.7 meters (22 feet) east to wat and has a 4.9-meter (16-foot) ceding height. The north and south walls of the room are 20-centimeter (8-inch) thick concrete that extend upwards to enclose that portion of the buflding’s duct level that serves the WC-line. The east and west wrdls are made of roof decking. The ceding is made of 2-centimeter (0.75-inch) thick plaster I on wire lath. Two doors lead from room 230A into room 228C on the east, two doors lead to room 230B on the west (one double door on the main floor and one on a partial mezzanine), and a double door opens into Corridor 6. i I Glovebox HC-21A, located in Room 230B, is 3.25 meters (10 feet, 8 inches) long and 1 meter (3 feet, 3 inches) wide at the base. The top is 0.9 meter (3 feet) above the glovebox floor. The glovebox rests on an open framework such that the floor of the glovebox is approximately waist high to an operator s~ding on a meti platform. Slanted windows on the west side give operators better visibility. Lights are mounted outside the top window on the glovebox; windows on the east side provide additioti light and visibility. An opening in b the north end of the glovebox provides access to conveyer glovebox HC-2. Air is supplied from the conveyer and exhausts through a duct in the ceding of glovebox HC-21A into the E-4 ventilation system.
Other equipment located in rooms 230A and 230B includes a portion of glovebox HC-2. Glovebox HC-2 is a conveyor that extends tito and beyond adjacent rooms 228C and 230C. Utfiities and services provided to room 230A include electrid power, fire protection
P
DOE~A-0978 2-5 October 1994 U.S. Depmtient of Energy Description of tie Proposed Action
(wet sprinkler system), and E-3 and E-4 ventdation. Figure 4 shows the location of glovebox HC-21C in room 230A and glovebox 230B in room 230B.
2.3.3 Glovebox HC-21C
Glovebox HC-21C is 3.25 meters (10 feet, 8 inches) long and 1 meter (3 feet, 3 inches) wide at the base with the top 0.9 meter (3 feet) above the glovebox floor. The glovebox rests on an open framework such that the floor of the glovebox is approximately waist high to an operator stiding on a meti platform. Slanted windows on the east side give operators better visibtiity. Lighw are mounted outiide the top window on the glovebox, whtie windows on the west side provide additiond light and visibility. An opening in the north end of the glovebox provides access to conveyer glovebox HC-2. The conveyer I extends from Glovebox HC-18BS in room 228C to near Glovebox HC-60 in room 230C. Air is supplied from the conveyer and exhausted through a duct in the cetiing of Glovebox HC-21C into the E-4 venttiation system. A hdon fwe suppression system services the glovebox. This system is set to activate at an air temperature of 74 ‘C (165 ‘F).
Glovebox HC-21C houses two standard laboratory size 4,000-watt muffle furnaces. The ou~ide of the furnaces measure 46 centimeters wide by 40 centimeters high by 61 centimeters deep (18 inches wide by 15.5 inches high by 24 inches deep). The furnace I chambers inside measure 14 centimeters wide by 13 centimeters high by 33 centimeters deep (5.5 inchw wide by 5 inches high by 13 inches deep). A muffle furnace is heated by electric elements surrounding the chamber, which is faced with firebrick to separate the contents from the elements. Heating is controlled by electronic controllers that slowly ramp the heat up to the required temperature. The controllers have high and low deviation logic systems that monitor process temperature in the furnace and remove power from the furnace if this temperature falls outside the expected range. Temperature detectors mounted in the glovebox would be connected to the controllers to prevent the glovebox from reaching the temperature that activates the fire suppression system. Offgases would be drawn off the furnace, using the buflding vacuum system, through an approximate l-centimeter (0.50-inch) diameter tubing, cooled and then passed into the E-4 ventdation system. Carbon dioxide or inert gas would be piped into the finaces at a rate of 0.8 to 1.6 metef per hour (30 to 60 fee? per hr during part of the heating cycle to reduce the potential for flammability of the offgmes during processing. The inert gas flow would cease when gaseous products are no longer generated, at about 300 ‘C (572 ‘F).
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U.S. Depmtient of Energy Mtewtives to tie Proposed Action
3.0 Alternatives tothe Proposed Action
I 3.1 No-Action Mternative
The No-Action Mternative consists of not stabilizing-the plutonium-bearing sludges at this time. The sludges would remain in unshielded process gloveboxes. The workers would continue to receive radiation doses during required glovebox operations such as monitoring the condition of the containers, accounting of the material, routine housekeeping, and preventative maintenance. Ml the PFP workers would continue to receive approximately 4 person-rem per year from the presence of sludges in unshielded gloveboxes.
In addition, shielded glovebox space would not be avtiable for ventilation duct cleanout. It is estimated that cleaning out the ventilation ducts would reduce worker exposure for PFP workers approximately 4 person-rem per year (ENert 1993). Both of these activities would reduce PFP worker exposure 8 person-rem per year. The No-Action Mtermtive corresponds to 0.004 LCFS per year for the PFP workers untfl both cleanup actions occur. The No-Action Nternative would not meet the dud need of reducing worker I exposure and of increasing shielded glovebox storage space to support future cleanup ‘1 activities. i I I 3.2 Disposal Mternative
The disposd alternative would dispose of tie sludges as a retrievable waste form before a fina~decisi;n has been made regarding the ultimate disposition of plutonium-bearing materials. Disposal of this amount and class of material is not allowable according to DOE Order 5633.3A, Control ad [email protected] NuclearMateriak (DOE 1993b). This type of plutonium-bearing material requires safeguards to prevent unauthorized diversion or thefi. In accordance with the referenced Order, this category of material is rdso not eligible for disposition as waste unless a vulnerability assessment demonstrates that there is not a risk of diversion or theft. However, if rdlowable the most likely disposd process for these solid , sludges would be to cement the solids in a form that meets Waste Isolation Pflot Plant ~PP) disposd criteria.
The process would involve dfluting the materials, mixing them with a concrete-type of I ‘1 materird, and then pouring tie mixture into 0.5-liter (l-pint) containers. The containers would then be packaged into 208-liter (55-gdon) drums for storage. The current WPP limit for plutonium stored in a drum is 100 grams (0.22 pounds) per drum. Disposal of the sludges would generate approximately 250 drums of waste.
Cementing the sludges would result in about 5 person-rem for the workers to cement the sludges and package the containers into 250 drums. This would rwult in 0.002 LCFS among the workers.
DOE~A-0978 3-1 October 1994 U.S. Depament of Energy Mternatives to tie Proposed Action
These 250 drums would be stored in one of two facilities (Centr~ Waste Complex [CWC] or Transuranic Waste Storage and Assay Facfiity ~USAF]) on tie Hanford site untfi ~PP starts accepting wastes. The interim storage location of these drums would be based on the curie content and security classification of the waste in the drum.
The toti volume of the waste is relatively small. However, because of its high curie content, this waste would consume approximately 60 percent of the toti waste storage capacity for allowed radionuclides within the CWC. The TRUSAF does not have a curie limit, and has sufficient space to accept the 250 drums (toti capacity about 2,000 containers). Both facilities are operating in interim stitus under the Resource Conservation and Recovery Act (RCRA) of 1976 and WmhingtonAdministrative Code WAC) 173-303. The waste created from the sludge would use a large proportion of the capacity of either the CWC (60 percent) or TRUSAF (12.5 percent) whfle awaiting the opening of the ~PP. In addition, current DOE directives do not allow this amount and classification of special nuclear material to be stored in TRUSAF or the CWC. For these reasons, this alternative is not desirable.
3.3 Processing Mternative
There are several processing alternatives that would stabfiize the sludges and free up glovebox space. These include operating the PRF and vitri~ing the sludges. Some of these alternatives are viable; however, they are more expensive; are simflar to historical defense production processes at PFP; in some instances, would make the processed material incompatible for future disposition; and would expose the operating stiff to subs~tidly higher doses of radiation ~ogt 1994). The sludges would sttil need constit handling with the accompanying worker exposure whtie a process is developed and prepared. For these reasons the alternatives would not meet the immediate need of reducing worker exposure.
3.4 Offsite Treatment and Storage of Sludges Mternative I
The Offsite Treatment and Storage of Sludges alternative would involve transporting the sludges to an offsite factiity for treatment and disposd. However, existing regulations prohibit offsite transport of unstibfiized f~sfle materials. Mso the transportation of this material on public roads would require packaging not yet developed to meet transportation requirement (49 CFR 173.416 and 173.417. Accordingly, this alternative has been dismissed from tither consideration.
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U.S. Depatient of Energy Affected Environment
4.0 Affected Enfioment
This section provides a description of the environment on the Hanford Site and the area surroundhg the PFP complex.
4.1 Plutonium Finishing Plant Complex
The PFP complex houses a number of operations involved in the recovery and chemical conversion of plutonium. These operations include laboratories, plutonium processhg, waste treatment, and nuclear material management. The complex is lomted within a secured area in the 200 West Area of the Hanford Site.
4.2 Location and Regional Population
The Hanford Site covers approximately 1440 square Mometers (560 square reties) in southcentrd Washington Stite (Figure 1). The City of Rictiand is the nearest population center and adjoins the southernmost portion of the Hanford Site boundary. Rictiand is about 40 air kilometers (25 air ties) from the PFP. The population within 80 Wometers (50 miles) of the H@ord boundary is estimated to be 380,000 to 400,000 based on the 1990 census.
4.2.1 Regional and Site Activities
Other government facilities on the Hanford Site include: the shutdown N Reactor, the deactivated Plutonium-Uranium Extraction @URE~ plant, U Plant, waste management facilities, nuclear materials storage facilities, research laboratories, and the Fast Flux Test Facility (FFTF). There are dso eight retired production reactors and three retired irradiated materials processing plants on the site. ‘
Commercial use of the Hanford Site includes a nuclear power plant operated by Washington Public Power SUpply System and a low-level radioactive waste burial area operated by U.S. Ecology and admtitered by the State of Washington. The Siemens Nuclear Power Corporation fiel fabrication plant is adjacent to the southern boundary of the site.
Agriculture is the main industry within a 80-Uometer (50-mfle) radius of Hanford. Other industries include a meat pactig plant, food proc~sing facilities, a ferttiizer plant, a pulp and paper mfll, a chemical plant, hydroelectric darns, and various small manufacturing firms.
4.2.2 Physicrd Envkornnent
The Hanford Site is located in the Pasco Basin, one of the structural and topographic basins of the Columbia Plateau. The region is semiarid and consists of clusters of industrid
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butidings that are widely separated by large areas of undeveloped land, including abandoned agricultural areas. Plant and animal species are representative of those inhabiting the sagebrush-grass region of the northwestern United States @NL 1992a).
The Columbia River flows through the northern part of the Hanford Site and along the eastern boundary. Grade level at the PFP complex is more than 60 meters (200 feet) above the maximum probable flood which is well above the 100-or 500-vear. flood. The PFP complex is not located in a wefland or a floodplain.
The only surface waters present in the 200 West Area are temporary waste water ponds and ditches. This water either enters the groundwater or evaporates.
Groundwater under the Hanford Site is present h both uncotilned and confiied conditions. The unconfined aquifer is contained within tie Ringold Formation. Its sources of natural recharge are rainfall and run-off from the higher bordering elevations, water infiltrating from small ephemeral streams, and tiuent river water. Confiied aquifers consist of sedimentary interbeds and interflow zonm that occur between dense basalt flows in the Columbia River Basalt Group. Groundwater at the 200 West Area is between 55 to 95 meters (180 to 310 feet) below grade and is routinely monitored by the Pacific Northwest Laboratory.
The Hanford Site lies in a Zone 2 seismic area which implies a potential for moderate damage from an earthqu~e. The largmt earthqu~e of record to occur within the Columbia Basin, the 1936 Mflton-Freewater earthqu~e, had a magnitude of 5.75 on the Richter Scale.
The regiod climate is characterized by relatively cool, mfld winters and warm summers. Average mtium and maximum temperatures for January are -50 and 3‘C (22° and 37°F). July’s average low and high temperatures are 16° and 33‘C (610 and 91‘F). Average annual rainfall is 15 centimeters (6 inches) and the average annual evaporation rate is 135 centimeters (53 inches).
Prevailing winds are from a northwesterly direction. Tornadoes rarely occur in the I region. The few that have been sighted were small and did not cause any damage. The probabtiity of a tornado hitting a particular structure on the Hanford Site is about 1 chance in 100,000 years. Airborne particulate concentrations can reach relatively high levels in eastern Washington because of exceptioti natural events such as dust storms and large brush fires.
Atmospheric dispersion conditions of the area vary between summer and winter months. The summer months gener~ly have good air mixing characteristics. If the I prevailing winds from the northwest are light, Ims favorable dispersion conditions may occur. Occasioned periods of poor dispersion conditions of stagnant air occur during winter months. \ The immediate area within a security fence surrounding the PFP is under vegetation control and is sprayed with herbicide at least annually to control noxious weeds. The only vegetation present is a lawn surrounding an administrative butiding. Robins, western I
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kingbirds, barn sw~lows, starlings, and cottontatis have been observed in the immediate area.
The 200 West Area near the PFP, oukide of the security fence, is mosfly sagebrush habitat consisting of scattered shrubs with understory of cheatgrass and sandberg’s bluegrass, with a large ricegrass component. Bird species observed in the vicinity include horned lark, western meadowlark, Say’s phoebe, rock dove, and starling. Coyotes and rabbits have been observed in the area.
4.3 Cultural Resources
The proposed action wtil not have any impact on cultural r~ources. Ml activities wfll take place in an existing facfiity. In addition, no modifications of the butiding are required. The ~nstilation of muffle tinaces in Glovebox HC-21C is not considered a Federd undertaking, { as defiied in 36 CFR Part 800. The planned operation wfll not affect the historical integrity of the facflity if it is determined to be eligible for the National Register of Historic Places. See Appendix C for the cultural rmources determination.
DOE~A-0978 43 October 1994 I —. —— U.S. Department of Energy EnviromnenW hpacts 5.0 Envkomental hpacts
Environment impacts from routine operations and potential accidents are discussed below. There are no project construction-related impacts because operations wfll tie place within the existing facflity. Minor modifications are required to place tinaces and anctilary equipment in existing gloveboxes.
5.1 Mr Emissions
Some chemical and radiological air emissions would be produced from the furnace offgas. The following sections discusses the impacts horn these.
5.1.1 Radionuctide Ah Eruissions ( Offgas would be exhausted from the furnaces using the plant process vacuum system. , This offgas would contain small concentrations of suspended radionuclide particles, primarfly plutonium oxide, from the stabfltition process. The offgas pollution control system includes a stitered meti falter at the exit of the furmce to remove the large particles. The offgas would then enter the E-4 ventilation system which includes two stages of HEPA fdtration. Each stage of HEPA fdtration removes at least 99.95 percent of the remaining
,’ 0.3 micrometer or larger radionuclide particles passing through them. The offgas would contribute a very small percentage (approximately 0.05 percent) to the toti plant exhaust flow.
b’ The radionuclide emissions resulting from operation of the tics are expected to be ! extremely low after passing through the two HEPA falters and would not result in a detectable increase in toti plant emissions. Historictiy, the toti plant emissions have not varied significantly with different operations in process, including previous furnace stabtii~tion operations. The toti plant emissions result from continuous ventilation of dl the process areas and gloveboxes within the PFP. Therefore, it is assumed that the health effects from historical toti plant emissions wfll be much greater than that resulting from just the sludge stabfii=tion process, and this data wfll be used as a bounding case to evaluate the hedti effects for the proposed action. I ‘1 The CAP88PC computer program from the U.S. Environment Protection Agency (EPA) and the Hanford specific GENI computer program were used on the PFP annual radionuclide emissions from 1983 through 1991 to estimate radiation dose and LCFS to the ., offsite population within 80 tiometers (50 reties) of the PFP. The information is shown in 1 ,, Table 3. The LCF estimated health effect is the product of the dose and the factor 0.0005 LCF per person-rem, which comes from ICW 60.5 f I
,i s me hternationrd Co~ssion on Wdiologicrd Protection CCM) has determined that the no- cancer fatrdity coefficient for low dose, low dose rate whole body irradiation is approtitely 0.0004 LCF/person-rem effective dose equivrdent @D~ for a worker poptiation and approtitely 0.0005 LCF/person-rem EDE for a population of rdl ages OCM 1991). H4th effects (i.e., LC~ are computed by mtitiplying the radiologiti dose by the IC~ coefficient.
DOE~A-0978 5-1 October 1994 U.S. Department of Energy Enviromenti hpacts
For comparison, an LCF of 1 would indicate that one cancer fatiity would be expected to occur in the exposed population as a result of the radiation exposure.
I It can be seen on Table 3 that the estimated LCFS to a member of the public due to one I year of PFP operations is very low; i.e., an average LCF of 0.00005 for the approximate ~! 400,000 population within 80 tiometers (50 mfles) of the PFP. It is extremely unlikely that I even one fati cancer could have been induced by the operations at PFP over the past nine
I years. It is even less likely that a LCF would occur specifically as a result of the sludge
, stabtiization operation. Appendix A provides the analysis of the historical plant emissions. I Table 3. Amud Plutotim Hhiug Plmt CoUective Dose md Health Effect.
Year Person-rem LCF
1991 0.0868 0.000043 1990 0.0604 0.00003 1989 0.0601 0.00003
1 1988 0.0343 0.000017 1987 0.0541 0.000027 i I 1986 0.593 0.0003 i 1985 0.021 0.00001
I 1984 0.0208 , 0.00001 I t 1983 0.0367 0.000018 I
I 5.1.2 Chetid Air Etisiom
Operation of the stabilization process would dso generate gaseous chemical emissions I which would be discharged from the main ventilation stack. These emissions for a typical I batch being stabilized would consist of about 9 grams (0.02 pounds) of butene from decomposition of organic materials and about 90 grams (0.2 pounds) of nitrogen oxides from decomposition of nitric acid and meti nitrates. The ody other emissions would be less than 230 grams (0.5 pounds) each of carbon dioxide and water. i The onsite and offsite chemical concentrations for these batch emissions (except water) were modeled assuming a continuous operation averagtig four batches per day. These concentrations are shown in Tables 4 and 5 below, along with comparison to any applicable Threshold Ltit Values - both the Time Weighted Average ~LV-TWA) (NOSH 1990) and the Short Term Exposure Limit flLV-STEL) (ACGIH 1991), or Acceptable Source Impact hvels (ASILs) WAC 173-460, 1991). TLV-~A is a me=ure of the chemical
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concentration level to which a worker can safely be exposed 8 hours per day, 40 hours per week. The TLV-STEL measures the safe exposure level to a worker for a fifteen minute period. Both of these limits are applicable to onsite concentrations. The ASIL is a measure of safe exposure level to the public, and is therefore applicable to offsite concentrations. The predicted chemical concentration levels range horn a factor of 100,000 to 1,000,000,000 below tie applicable TLV-~A, TLV-STEL or ASIL values.
Table 4. Chemicrd Concentrations at the Maximum Onsite Receptor Locations Based on 99.5 Percent Meteorology and Comparison to TLV-TWA and TLV-STEL Limits. T-m NOX 0.0000062 5.6 . 0.000016 9.4 Butene 0.00000062 NA 0.0000016 NA 3C02 ~0.000016 9000 0.00004 54000 ~ Table 5. Chemid Concentrations at the Maximum Offsite Receptor Locations Based on Annual Average Meteorology and Comparison to AS~ Vdu~.
Chemical Concentration ASIL (24 hr) (mg/m3) (mg/m3)
NOX 0.0000005 0.1 Butene 0.00000005 NA Carbon Dioxide 0.0000013 NA
5.2 Worker Radiation Exposure
The proposed action would result in a reduction of approximately 4 person-rem per year for dl of the PFP operators, plus allow ventilation ductwork cleanout, which would ~esult in an additiod 6 person-rem reduction per year. However, the proposed action would result in radiation exposure to the workers when they perform operations involving close proximity to the sludges. It is estimated that the procms wtil require three individuals per shift to spend one hour working in the proximity of the sludges (whale at the gloveboxes, during transport of materials or during packaging). The composite whole body dose rate is expected to be about 10 mtilirem per hour. This proc~s is planned to be operated on a three shift, seven day per week basis. At the expected processing rate of two batches per furnace
DOE~A-0978 5-3 October 1994 U.S. Department of Energy Environrnenti hpacts
per day, and assuming that 20 percent of the material must be recycled through the process, the cumulative dose would be 17 person-rem for the duration of the stabilization action. This would result in an estimated health effect of approximately 0.007 LCF for the directly exposed workers.
Workers are subject to routine radiation exposure from many of the operations within the plant. The radiation exposure resulting horn the proposed action would be cumulative with exposures received from other operatiom. The radiation exposure of each operations worker is limited to no more than 2.0 rem per year, with administrative controls (HS-RCM, article 212) and a worker monitoring program which provide hold points starting at a cumulative exposure to any worker at 0.5 rem. There are adequate operations staff at PFP to perform the proposed action and other reasonably foreseen plant activities within this dose limit.
5.3 Solid Waste I
The sludge stabilization process would generate a small amount of radioactive solid waste. This would r=ult from disposd of the polyjars in which the sludges are currently stored. There would dso be waste from the sedouts, sample analysis work, and other miscellaneous activities. Solid wrote generation would be minimized in accordance with the current PFP waste minimization program. The volume of solid radioactive waste is estimated to be 0.01 cubic meter (0.5 cubic foot) per day at the expected processing rate. Approximately 4.3 cubic meters (150 cubic feet) of the waste would be stored or disposed at the Hanford Central Wrote Complex.
5.4 Accident Potential
Two potential accidents were dyzed for operation of the sludge stibflization process: a major fue in the glovebox and a flammable gas deflagration. Both accidents have a probabtiity of occurrence of 0.00001 or less. The estfiated probability for either accident leading to a release of radioactive materials is the same, and the consequences from the ~ flammable gm accident would be slightiy higher; therefore, this was evaluated as the bounding accident. More detafis on the dysis of both accidents are provided in the letter analysis report @amble 1994). ~
5.4.1 Accident Scentio I . Flammable gas (i.e., butene) would be generated during sludge stabdization operations I due to the presence of tributyl phosphate in certain feedstocks. Tributyl phosphate decomposes slowly at temperatures just above 110 ‘C (230 ‘F) and the decomposition rate \ increases as the bofling point is approached (268 ‘C [514 ‘F]). The major gaseous products I from the thermal decomposition of tributyl phosphate are butene and water.
An Operations Specifications Document for HC-21C would limit the tributyl phosphate content of feed materials to a maximum of 2 percent by weight. This equates to
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10 grams (0.02 pounds) for a 500-gram (1.1 pound) charge. A cover gas, carbon dioxide or inert gas, would be fed to the timce during the processing of charges containing organic material. The cover gas acts as a dfiuting gas to reduce the oxygen concentration such that the lower flarnmabfiity limit (LFL) of butene is not reached in the furmce offgas. me LFL is defined as the minimum concentration of vapor in air at which propagation of a flame wfll occur on contact with a source of ignition.
For this analysis, it is assumed that 20 grams (0.04 pounds) of tributyl phosphate are present in the charge. This value is conservatively chosen to account for an error in charging the boat or an error in determining the concentration of tributyl phosphate present. It is further assumed that the cover gas is absent, that the furnace offgas is blocked, and that the controller fatis in such a manner that dl of butene potentitiy avatiable is evolved instantaneously.
The amount of butene generated given 20 grams (0.04 pounds) of tributyl phosphate present in the charge is 12.6 grams (0.03 pounds). The butene generated is conservatively assumed to form a flammable mixture in the glovebox and ignite. The resultant deflagration is conservatively assumed to breach the glovebox releasing material into the surrounding room.
5.4.2 Probabfi@
The annual probabtiity of occurrence (i.e., frequency/year) of the postulated deflagration is estimated to be 0.00001 or less. This estimate is based in part on the human errors and equipment faflures required for the event to occur as postulated. These include:
● an error in determining the concentration of tributyl phosphate resulting in twice the normal maximum quantity of tributyl phosphate being present
● inadequate cover gas flow to tie furnace; this could result from human error or equipment faflure (valve fafls closed)
● inadequate furmce offgas flow; this could result from human error or equipment fafiure
. controller ftiure or programming emor such that the furmce heats at ifi maximum rate
. controller fatiure (independent from that above) or programming error such that the high temperature deviation interlock does not remove power from the furnace
In addition, the assumption that a butene deflagration occurs is conservative. It is important to note that the assumption that a butene deflagration sufficient to breach the glovebox occurs is believed to be conservative. In a simflar accident Aysis performed for Glovebox MT-5 (located in the Plutonium Reclamation Factiity of PFP), precise modelling of the butene generation rate and glovebox atiow patterns found that flammable concentrations are not physically possible (Shapley 1994).
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5.4.3 Source Term
Using the worst-case assumption that butene would produce a deflagration equivalent to T~, the ignition of 12.6 grams (0.03 pounds) of butene in the glovebox would disperse 126 grams (0.3 pounds) of plutotium. It is further assumed that the entire amount is plutonium of a respirable particle size. @ote that the weight percent of plutonium in plutonium oxide is 88 percent but this dysis assumes consematively that the material is 100 percent plutonium.)
The 126 grams (0.3 pounds) of airborne plutonium is conservatively assumed to be expelled into room 230A. @edisticWy, some of the airborne plutonium would be drawn I into the glotiebox ventilation system which provides an additiond stage of filtration.) I Room 230A is serviced by the E-3 ventilation system that provides one swge of HEPA filtration prior to discharge out the 291-Z stack. The resulting release to environment through the fiitered ventilation from a butene deflagration in glovebox HC-21C would be 0.048 grams (0.0001 pounds) of plutonium.
Applying the approach used for the Glovebox MT-5 safety analysis, the ignition of ‘1 12.6 grams (0.03 pounds) of tributyl phosphate in HC-21C would disperse 35 grams of plutonium into room 230A, and hence an even lower release to the environment. ,1
5.4.4 Accident Comequences
Based on the release of 0.048 grams (0.0001 pounds) of plutonium out the PFP stack, the maximally exposed onsite individud would receive an effective dose equivalent (EDE) of 0.015 rem and the maximally exposed individud at the site boundary would be exposed to an EDE of 0.0016 rem. The population exposure and related health effect are shown in Table 6. Based on the estimated LCFS it is very udikely that there would be even one cancer fatiity from exposure resulting from the postulated accident.
Table 6. Herdth Effecfi from Accident Scenario.
I Sector Exposed Committed Health Effec@ I Population Effective Dose Equivalent 140 3.58 person-rem 0.0015 LCF
I I Worst Case Offsite SE 114,734 21.5 person-rem 0.011 LCF , Population i
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An estimate of the consequences to the two to three workers present in room 230A is based on several assumptions. The plutonium is expelled throughout the room immediately, and the workers inhale some of the plutonium before they exit the room. (In the event of airborne contamination, the workers are trained not to breathe before exiting the room.) I There would be no physicrd impact outside of the plant. The accident would likely
I result in equipment damage and physical injury to workers-in the room and contamination ~i spread to adjacent arem within the buflding, but tie secure, reinforced room would limit ‘1 physical impact. I
5.5 Socioeconomic hpacti
Noise levels would be comparable to existing conditions at the PFP. The amount of equipment and materials to be used represent a minor long-term commitment of nonrenewable resources.
The proposed action is not expected to impact the climate, flora and fauna, air quality, geology, hydrology and/or water quality, land use, or the population. The cultural resources ;t review supports these expectations.
Stabtiizing these sludges would not require additioti workforce. Therefore, no socioeconomic impact is anticipated.
5.6 Cumulative bpacti
Ongoing or planned activities omurring on the Hanford Site are numerous. The predominant activities that are either ongoing or planned within the foreseeable future involve environment restoration and waste management activities. The proposed action is closely allied with other waste management activities. The Hanford Site maintains a site environment monitoring program that routinely monitors radioactive air emissions.
5.6.1 Cmtiative hpati - ~ ~afioactive)
In calendar year 1991, the rel=e of plutonium-239/240 to the atmosphere from the 200 Areas was very small, approximately 0.00044 curies. The atmospheric emissions from plutonium-239/240 in 1995 are expected to be equal to or ltis than the emissions that were released in 1991.
Offgases resulting from the proposed action would contain small concentrations of suspended radionuclide particles, primarfly plutonium oxide. As a result of the pollution control system (i.e., sintered meti fiiter, E-4 ventilation system, and double-stage HEPA ftitration system), additioti radionuclide emissions to the atmosphere, as a result of the proposed action would be extremely small.
DOE~A4978 5-7 October 1994 U.S. Depa~ent of Energy Enviromenwl hpacts
Under normal operating conditions, radionuclide air emissions msociated with the proposed action would fdl below air permit requirements and would not be expected to result in any measurable increase in radiological emissions at the Hanford site. It is unlikely that even 1 LCF would occur as a result of the proposed action.
5.6.2 Cmtiative hpacfi - SoEd WWe
The proposed action would generate approximately 0.01 cubic meters (0.5 cubic feet) of radioactive solid waste per day, which would be stored or disposed of in the Hanford Central Waste Complex. This waste would represent a very small increment increase in the toti amount of waste that is stored or disposed of on a dafiy basis at the Hanford site.
The storage and disposd of this waste would be in accordance with applicable regulations (see Section 6.2, Solid Wastes) that govern the storage and disposd of huardous and radioactive waste at the Hanford site.
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1 DOE~A4978 5-8 October 1994
.-, - .——
U.S. Department of Energy Re@atory Provisions Comidered
6.0 Permits and Re~latory Requirements
The Sludge Stabfliation operation would be carried out in accordance with the DOE’s environmenml policy, which is “to conduct its operations in an environmentily safe and a sound manner.. .in compliance with the letter and spirit of applicable environment statutes, regulations, and standards” (DOE Environment Policy Statement DOE N 5400.2). The action would be consistent with dl applicable laws, regulations, and compliance agreements, as outlined below.
6.1 Air Quality
Air emissions from the PFP would comply with the Natioti Emissions S~dards for H-dous Air Pollutants permit administered by the U.S. Environment Protection Agency, the Radioactive Airborne Emissions Program permit administered by the State of Washington Department of Health, and the nonradioactive air permit administered by the State of Washington Department of Ecology. In a meeting with Washington Department of Health personnel on June 12, 1994, it was determined that a Notice of Construction is not required for this action, as the action does not constitute a new activity at tie PFP. A simtiar process has been operated in the past in another glovebox at the PFP.
6.2 Solid Wastes
The applicable regulation is WAC 173-303, “Washington Dangerous Waste Regulations. ” The EPA has delegated authority to the State of Washington, Department of Ecology, for dangerous-waste regulations which include the RCRA interim and fti status permit program for hazardous wastes. The PFP is managed under RCRA Interim Status for dangerous waste treatment and storage at the 241-Z factiity. The PFP dso generates and manages containerized solid waste (non-regulated, dangerous waste, and radioactive mixed waste) in accordance with WAC-173-303 and RCRA requirement. These regulations would be applicable to any solid wastes generated from the stibdtition process. Waste regulations are not directly applicable to the sludges or the stabilization process, as tiese sludges may not be declared as waste untti the fti disposition of special nuclear materials is determhed.
6.3 Hanford Federal Facility A~eement and Consent Order
The applicable compliance agreement is the HanfordFederal Faciliq Agreement and Consent Order @ri-Party Agreement), EPA Docket Number 1089-03-04-120, Ecology Docket Number 89-54. The Tri-Party Agreement, signed by the EPA, DOE, and Washington Stite Department of Ecology, sets forth schedules and mfi=tones for CERCLA and RCRA cleanup activities and compliance actions across the Hanford site. The PFP is committed to meeting dl applicable Tri-Party Agreement destones. Ongoing negotiations may add Tri-Party Agreement milestones for the cleanout of the PFP.
DOE~A-0978 6-1 October 1994 — -—
U.S. Depa~ent of Energy Cotitition / Coordimtion
7.0 Agencies Consulted
Before the EA was written, several informal meetings were held with tribes and stieholders, including regulatory agencies and public interest groups. Thwe meethg were to inform the stieholders of proposed PFP activities and receive informal r~ponses. The meeting dates and participants are summarized in Appendix D.
Early draf@ of this document were sent out to tribes and stieholders in May 1994. One set of written comments was received from the Washington Department of Health, which were responded to at a routine montiy interface meeting with Washington Department of Health personnel on June 12, 1994. During the meeting, it was determined that a Notice of Construction is not required, as the action does not constitute a new activity at the PFP. A simtiar process has been operated in the past in another glovebox at the PFP.
A fii draft of this document was sent to the Washington State Department of Ecology, the Y-a Indian Nation, Nez Perce Tribe, Confederated Tribes of the Umatflla Indian Reservation, the Wanapum and other inter~ted parties on September 12, 1994. Written cornmenh were received from Ecology and Confederated Tribes of the Umatflla Indian Reservation. A meeting to clarify the comments was held between Ecology and U on October 13, 1994. The commenk and responses are found in Appendix E. No other written comments were received h response to the fti draft document.
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DOE~A-0978 7-1 October 1994 I —— .. —-—-—. . . ~
U.S. Dep~tient of Energy References ,
8.0 References
36 CFR 800, “ProtectionofHistorica ndCulturdP ropertim,” Code of Federal Regulations, as amended.
40 CFR 1500-1508, 1978, ''Regulation for Implementig tie Procedmd Provisions of tie National Environment Policy Act,” Code of Federal Regulations, as amended.
49 CFR 173.416 and 173.417, “Authorized Type B Pacbges, ” Code of Federal Regulations, as amended.
ACGIH, 1991, 1991-1992 ~reshoti Limit Valuesfor ChemicalSubstancesati Physical i Agents and Biological fiposure I&ices, American Conference of Government Industrird Hygienists Human Services, Cincinnati, Ohio.
Barney, G. S. and T. D. Cooper, 1994, me ~emistry of TributylPhosphate at Elevated Temperaturesin the PlutoniumFinishingPlant Process Vessek, WHC-EP-0737, Revision O, Westinghouse Hanford Company, Richhmd, Washington.
Certi, P. J., 1992, PreliminaryHazardsAnalysis of HA-211~ermal Scrap Stabilization Process, WHC-SD-CP-PHA-003, Rev. O, Westinghouse Hanford Company, Richhmd, 1 Washington.
CleanAir Act of 1977, as amended, 42 USC 7401.
Cleveltid, J. M., 1979, The Chemistryof Plutonium, prepared under the auspices of , the Division of Technid Information, United States Atomic Energy Commission, ,1 Washington D.C.
f ‘! Crowe, R. D. and R. W. Szempruch, 1994, TechnicalBasisfor Charatietization of Plutoniumfor PFP S@etyAnalyses, WHC-SD-CP-TI-190, Wwtinghouse Hanford Company, RicMand, Washington.
DOE, 1988a, R&iation Protection of the Public ad Environment, DOE Order 5400.5, U.S. Department of Energy, Washington, D.C. ,,
‘/ DOE, 1988b, Radiation Protectionfor OccupationalWorkers, DOE Order 5480.11, U.S. Department of Energy, Washington, D.C.
DOE, 1993a, RecommendedValues and TechnicalBasesfor Airborne Release Fra~’ens, Airborne Release Rates, and RespirableFractiom at DOE Non-Reaoor Nuclear Facilities, DOE-HDBK-0013-93 (Draft), U.S. Department of Energy, Washington, ‘1 D.C.
DOE, 1993b, Control and Accountabilip of NuclearMateriak, DOE Order 5633.3A, U.S. , Department of Energy, Washington, D.C.
DOEEA-0978 8-1 October 1994 U.S. Dep~trnent of Energy References
Eckerman, K. E., A. B. Wolbarst, and C.B. Richardson, 1988, Limiting Values of RadionuclideIntake and Air Concentrationand Dose ConversionFactorsfor Inhalation, Submersion, ati Ingestion, EPA-520/l-88-020, Oak Ridge National Laboratory, Oak Ridge, Tennessee.
Ecology, EPA, and DOE, 1992, HanfordFederalFacilityAgreement and Consent Order, 2 vols., Washington State Department of Ecology, U.S. Environmental Protection Agency, and U.S. Department of Energy, Olympia, Washington.
Ecology, EPA, and DOE, 1993, TentativeAgreement on Tri-Pa~ Agreement Negotiations, October 1993, Washhgton State Department of Ecology, U.S. Environmentrd Protection Agency, and U.S. Department of Energy, Olympia, Washington.
Etiert, A. L. 1993, to E. C. Vogt, “Increasing Worker Exposure to Americium-241 and Other Material in PFP, ” Interti memo PFP/LAB HP 33920-93-039, dated May 25, 1993, Westinghouse Hanford Company, RicNand, Washington.
Etiert, A. L., 1994, to J. B. Hamflton, “Estimated Dose from Stabilization Operations, ” Interd memo dated January 19, 1994, Westinghouse Hanford Company, Rictiand, Washington.
Etiangered SpeciesAct of 1973, 16 USC 1531 et seq.
EPA, 1981, Compilationof Air PollutantEmissionFactors, Third Edition, AP-42, U.S. Environment Protection Agency, Washington, D.C.
EPA, 1992, Users Guidefor C~-88-PC, Version 1.0. Report No. 402-B-92-001, U.S. Environment Protection Agency, Washington, D.C. 4
Hdverson, M. A. and J. Mishima, 1986, Initial Conceptson Energetic and Mass Releases During Nonnuclearfiplosive Events in Fuel CycleFacilities, PNL-5839, Pacific Northwest Laboratory, RicMand, Washington.
Hey, B. E., 1993, ~Q Program Users’Guide, WHC-SD-GN-SWD-30002, Rev. O, and ~Q Program Validationand Ven~cation, WHC-SD-GN-SWD-3003, Rev. O, Westinghouse Hanford Company, RicNand, Washington.
Hey, 1994, AtmosphericDispersion Co@cients for PFPAccidentAnalyses, WHC-SD-CP-TI-191 Rev O, Westinghouse Hanford Company, RicMand, Washington.
ICRP, 1991, Annak of the IC~, Publication 60, Internatioti Commission on Radiologicd Protection, Ehnsford, New York.
National EnvironmentalPolicyAct of 1969 (NEPA), 42 USC 4321 et seq.
DOE~A-0978 8-2 October 1994 . .—.—.. —— . -. —. —.— — !,- ,,, , ,- U.S. Deparment of Energy References
Natioti Safety Councfl, 1992, Accident Facts, 1992 Edition, Itasca, IL: Author.
Napier, B. A., R. A. Peloquin, J. V. Ramsdell, and D. L. Strenge, 1988, GENH-me Hanford EnvironmentalRadiationDosimet~ So~are System, 3 VOIS., PNL-6584, Pacific Northwest Laboratory, RicNand, Washington.
NIOSH, 1990, NIOSH Pocket Guide to ChemicalHazards, U.S. Department of Health and Human Services, Washington, D.C.
NRC, 1982, AtmosphericDispersionModeh for PotentialAccident Consequencesat Nuclear Power Plants, Regulatory Guide 1.145, Rev. 1, U.S. Nuclear Regulatory Commission, Washington D.C.
PNL, 1991, HanfordArea 1990 Populationand 5&year Projecdom, PNL-7803, Beck, D. M., B. A. Napier, M. J. Scott, A. G. Thurman, M. D. Davis, D. B. Pittenger, S. F. Shindle, and N. C. Batis~o. Pacific Northwest Laboratory, RicNand, Washington.
PNL, 1992a, Hanford Site National EnvironmentalPolicyAct ~PA) Characterization,PNL-6415, Rev. 5, C. E. Cushing (Ed.), Pacific Northwest bboratory, RicNand, Wmhington.
PNL, 1992b, Hanford Site EnvironmentalRepoti for Calendar Year 1991, PNL-8148, UC-602, R. K. Woodruff, R. W. Hanf, and R. E. Lundgren, Pacific Northwest bboratory, Rlctiand, Washington.
Ramble, A. L., 1994, to L. H. Rodgers, “Glovebox HC-21C/MT-5 Compmison btter
( Analysis Report, ” Interti Memorandum 8D143-094-014, dated June 28, 1994, Westinghouse Hanford Company, RicMand, Washington.
,, I Resource Consewation and Recove~ Act of 1976 @CRA), 42 USC 6901 et seq.
SchrecWise, R. G., K. Rhoads, J. S. Davis, B. A. Napier, and J. V. Ramsdell, 1993, RecommendedEnvironmentalDose CalculationMethods and Hanford-Specl~c Parameters, PNL3777, Rev. 2, Pacific Northwest Laboratory, RicNand, \ Washington. I Shapley, J. E., 1994, MT-5 S@etyAssessment, ~C-SD-CP-SAR-012, Rev. 2, Westinghouse Hanford Company, RicNand, Washington.
Sudmann, R. H., 1991, PlutoniumFinishing Plant Final SafetyAnalysis Repoti, WHC-SD-CP-SAR-021 (Draft), Rev. O, W=tinghouse Hanford Company, RicMand, Washington. , Vogt, E. C., 1994, to J. E. Mecca, “Accelerated Disposal of Plutonium Bearing Sludge, ” btter 9403177B Rl, dated June 3, 1994, Westinghouse Hanford Company, RicNand, Washington.
DOE/EA-0978 8-3 October 1994 U.S. Depatient of Energy References 1 I
I WAC 173-303, 1984, “Dangerous Regulations,” of Ecology, Olympia, Washington.
WAC 173-460, 1991, “Controls for New Sources of Toxic Air Pollutants, ” Wahington Administrative Code, as amended.
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& DOE~A-0978 84 October 1994 I 1 I_ —. . . . .-. .Z ——...... i— -—..—————-— .—....— —. - .——1 -, . .- , ,. 7;L,- , ~, .::,-:.,”..~,.” , . ,., —
U.S. Depmtient of Energy Fi~es
Fi~res
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DOE~A-0978 October 1994 .-— —-— .—
, U.S. Dep~tient of Energy Fi~es
L L
Fi~re 1. Hatiord Site.
DOERA%978 F-1 October 1994 U.S. Depatient of fiergy Figures
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! FiWre 2. 200 West Area. (Tfi fi~e k not to sale.)
DOE~A~978 F-2 October 1994 L— ....—-- —. ——-.—— --..— U.S. Depatient of Energy Fi~es
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Figure 3. Remote Mechanical “C” Line Location tithin the Plutonium Finishing Plant Complex.
I DOE~A-0978 F-3 October 1994 U.S. Depatrnent of Energy Fi~es
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HC-21 C I
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Fi~re 4. Plot Plan for Rooms 230A and 230B. I I
I DOE~A-0978 F4 October 1994
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U.S. Depm~ent of Energy Appentix A
Appendk A -
motid Plutotim Mhg Plant Rafionutide Ah Etitiom Data
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DOE~A-0978 October 1994 —- .—-. — .— —
U.S. Depw~ent of Energy Appenaix A
Historical Plutonium Finishing Plant Radioactive Ar Emissions Data
The CAP88PC computer program from EPA was used on annual plutonium and americium emissions from the PFP to estimate radiation dose and fati cancer risk to the offsite population within 50 ties of the PFP.
The measured emissions are shown in the table below. The toti alpha emitting activity released each year is assumed to be 90 percent Pu-239 and 10 percent Am-241. Th=e are averages. The actual percentage ranges from 5 to 15 percent. The ti-241 toficiu ad movement in the environment are stiar to that of plutonium.
Am@ Plutotim Whg Plmt Mpha Etisiom.
1991 1.50x 10B 3.9 x 10’2 5.27X lV 5.85X 10S
1990 1.10x 10-13 3.7x 10U 3.66X 1~ 4.07x 10s
1989 1.17x 10M 3.46X 102 3.64x lV 4.05x 10s
1988 6.24X 1014 3.7x 10’2 2.08X ld 2.31X 10S
1987 9.85X 101’ 3.7x 10U 3.28X lW 3.64x 10s
1986 1.08X 1012 3.7x 1012 3.60X 103 4.00x ld
1985 3.82X 101’ 3.7x 10’2 1.27X lN 1.41x 105
1984 3.79 x 1014 3.7x 1012 1.26X ld 1.40x 10s
1983 6.69 X 1014 3.7x lo~ 2.23X lti 2.48X 10s
The CAP-88 computer program was fed Hanford Site wind data collected in the 200 Areas from 1983 to 1991. The population distribution is for people offsite, and is documented in Beck, D. M., B. A. Napier, M. J. Scott, A. G. Thurman, M. D. Davis, D. B. Pittenger, S. F. Shinde, and N. C. Batishko. 1991. HanfordArea 1990 [email protected] 50-year Projection, PNL-7803, Pacific Northwest Laboratory, Wctiand, Washington. The population table used was compfied from the 1990 census. The standard CAP88PC consumption and transfer parameters were used. The projected population dose for a unit release (1 curie per year) is shown below.
Note that some of the default parameters are sometimes modified to make the food consumption the same as what is used in the GE~I code. However, many parameters, such as the concentration ratios, cannot be changed. Since the dose from plutonium and americium is dominated by the inhalation pathway, rather than ingestion, the CAP88PC defaults were used. The improvements resulting from modification of some of the default parameters increase tie fti doses by less than 5 percent, a m-gless change.
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DOE~A-0978 A-1 October 1994 I I — -,t U.S. Depa~ent of Energy Appendix A
The table below shows the population doses computed by CAP88PC and GENII with one curie being released during a year. The two codes differ by only 10 percent because the ingestion dose is a minor contributor. Both codes were given the soluble forms of plutonium I I to use for both Mdation and ingestion. I
Poptiation Dose Factors, Person-rem/Ci.
I h-239 M-241 CM88PC 148 152 GW 160 170 i’
I The annual population doses are the product of the dose factors and the activity t released each year. These doses are listed in the table below. In addition, the estimated lifetime fati cancer risk is shown. This health effect is the product of the dose and the factor 5.0 x 104 latent mcer fatiities per person-rem, which comes from ICRP 60.
titi PFP CoMectiveDose and Health Effect. (exposed population is 375,860 people)
1991 8.68x 102 4.3x lo~ I 1990 6.04X 102 3.0x 10J
I 1989 6.01X 102 3.0x lo~ 1988 3.43x 102 1.7x lo~ I 1987 5.41x 10* 2.7X 10S
1986 5.93x 101 3.0x lW
1985 2.10x 102 1.0x 10$
1984 2.08X 102 1.0 x lo~
1983 3.67X 102 1.8X 10S
Y It can be seen on the above table that the potential risk to a member of the public from ●.> PFP operations is very low. It is extremely unlikely that even one fati cancer in a population of 375,860 could be induced by the operations at PFP over the past nine years.
GEMI Dose Calculation Program, Version 1.485 3-Dec-90, Napier 1988)
CAP 88- PC Version 1.00 Clean Air Act Assessment Package -1988 (EPA 1992) .1
DOE~A-0978 A-2 October 1994
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U.S. Depar~ent of Energy Appendix B
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I DOE~A-0978 October 1994
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U.S. Depx~ent of Energy Appendix B
Chemical Mr Emissions Dati
This appendix detatis the methodology used to estimate the onsite and offsite chemical concentrations due to emissions from PFP during sludge stabfltition operations. The estimated quantities of chemicals released during processing are shown in Table 1 below. Table 1 also includes estimated routine release rates based on procmsing 4 batches of sludge per day. This release rate assumes 4 batches of sludge are proc=sed continuously over a 24-hour period. Each batch weighs approximately 1 pound.
Table 1. Chemicrd Releases from the Plutonium Whing Plant During Sludge StabWation.
Chemicrd Quantity (lb~ Estimated Release Rate (mg/s)b
NO. 0.2 4.20 Butene I less than 0.02 I 0.42 Carbon Dioxide I less than 0.5 I 10.5 Water less than 0.5 10.5
n Quantity released due to processing one pound of sludges.
WRelease rate due to processing four batches over a 24-hour period.
Emissions &sumptions
Estimates of gaseous emissions from operation of HC-21C were dculated based on composition data supplied by Plutonium Finishing Plant Procms Control. Materials to be treated include sludges from the last Plutonium Recovery Factiity @RF) campaign, sludges from the PRF training run, and miscellaneous floor sweeps from remote mechanical line C @MC). Assumptions used for the calculations were: one polyjar processed per batch, polyjar wtil be no more than hdf ~, any carbon tetrac~oride initidy present has evaporated, the furnace wtil be operated in an atmosphere that supplies sufficient oxygen for complete oxidation, and dl sludges wfll be less than 2 percent organic. me m~um amount present has been used for each component.
I I , I DOE~A-0978 B-1 October 1994 I U.S. Depatient of Energy Appendix B
The density of the sludges is assumed to be 2 g/cc. This is based on the observation tiat when the andyticd laboratory contacts the sludges with carbon tetrachloride (density approximately 1.5 g/cc), the sludges remains at the bottom of the contiiner. The polyjars have a volume of 500 cc. If the polyiars are no more than hdf fill of sludges, the maximum amount of sludge treated at one t~e- wtil be 500 g. This is rounded to one-pound.
1 Gases that are expected to be generated in this process include nitrogen oxides from I nitric acid and meti nitrates, butene from butyl phosphates, carbon dioxide from organic I [ compounds and carbonates, and water vapor. As a semi-quantitative analysis of the materials, consider: If the sludges are less than 2 percent organic and we have one pound of sludges, stabtiking the sludges in HC-21C wdl generate less than 0.02 pounds of butene. The maximum nitric acid was 50 percent 3-5 molar HN03. Nitrates are dso present as up to 50 percent Fe(N03)3 and up to 39 percent Pu(N03)4. Because of the uncertainty in these estimates, if a conservative estimate of 50 percent concentrated nitric acid is assumed, then 0.2 pounds of nitrogen oxides wtil be generated per polyjar. The only other gases expected are carbon dioxide and water. Both of these are expected to be less than 0.5 pounds.
Release Scenario Description I I The chemicals released (Table 1) are assumed to enter the PFP ventilation system. The ventilation system exhausts to the atmosphere tiough the 200 ft (61 m) PFP stack. The stack flow rate is 260,000 scfm (123 m3/s) and the stack inside diameter is 13.5 ft (4.1 m) (Hey 1994). The release is modeled as a stack release, and momentum rise will be accounted for using the momentum rise model (Hey 1993). . Two types of dispersion calculations were made. The first modeled the release as a chronic release using 99.5 percent meteorology. For onsite receptors, credit was taken for plume meander based on an 8 hour releme using the fifth power law model (Hey 1993). The I resulting onsite concentrations were compared to the TLV-TWA values (ACGIH 1991), which are based on an 8 hour averaging time. For offsite receptors, credit was taken for plume meander based on a 24 hour release. The offsite concentrations was compared to the b’. Acceptable Source Impact Levels (ASILS) from WAC 173-460, which apply at the site boundary, and are based on a 24 hour averaging time.
The second dispersion calculation modeled the release as a short term release using 99.5 percent meteorology. The same release rate Cable 1) was used, however, the release ,1 duration was 15 minutes and no credit was taken for plume meander. The resulting onsite .1 concentrations were compared to the Short-Term Exposure Limik ~LV-STEL) from ACGIH (1991), which are based on a 15 minute averaging time. Note that there are no short-term concentration limits applicable to the public at the site boundary.
f I DOEEA-0978 B-2 October 1994
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U.S. Depatrnent of Energy Appendix B I
Resulfi of Dis~ersion C~culations
The GXQcode Version 3.1 C, Gener~Purpose Atmospheric Dispersion Code, (Hey 1993) was used to c~culate the onsite and offsite X/Q v~u~ based on the specified assumptions. C~culations were made for receptors at the nearest onsite facilities and for receptors at the site boundary. The distances to the onsite and offsite receptors are shown in Tabies 2 and 3 below ~C 1994) along with the resulting X/Q values.
Table 2. Distaucw to Nears Ofite Fatitiw ad X/Q Vduw for a Stack Releme from the Plutotium Mtig Plmt.
Dlstanee WQ (din’) from Nearat OnsiteFacility Stack 15 min. 8 M. (m)
272-WAm 630 ~ 3.85X 1~ 1.48x 106a
T-Plant~) 1580 1.44 x 106 5.49 x 107 f
2713-W~) 830 2.14 X ld 8.19X 107
U-Plant@E) 1060 2.51 X 1~ 9.60X 107 242S(SSE) 930 3.10x lV 1.19x 106
● MaximumorrsiteNQ basti on 99.5 pe~nt meteorology.
Table 3. Dktmcw to the Site Bouu@ ad Mtium X/Q Vrduw for a Stack Releme from the Plutotim Finisfig Plmt.
\ Transport D]stanw Transpofl Disbrrm @) Dirwtion m) (3:) Dlwtion (27:) (old) (s/d)
s 15.0 1.0 x 10’ N 19.2 7.80 X 108 Ssw 15.4 9.74 x 108 NNE 26.0 4.35 x 108
. Sw 16.1 9.24 x 108 NE 28.9 4.74 x 108
Wsw 13.2 1.02x 107 ENE 25.6 5.83 X 108
w 12.5 1.19x 1~’a E 25.2 6.17 X 108
13.2 1.13x 10’ ME 30.0 5.22X 10’
NW 16.5 9.09x lti SE 25.2 6.15X 10’
NNW 17.4 8.63X 108 SSE 22.9 6.51X 10a
a M~imum offsite X/Q based on 99.5 percent meteorology. I
DOE~A-0978 B-3 October 1994 U.S. Depatrnent of Energy Appendix B
The 99.5 percent X/Q takes into account we direction aspects of site meteorology, whereas the 95 percent X/Q does not. The 99.5 percent X/Q is that dispersion coefficient which is exceeded less than 0.5 percent of the time (44 hours a year) in any given 22.5 degree compass sector. The 95 percent X/Q treats each sector the same. The 95 percent X/Q is that dispersion coefficient which is exceeded less than 5 percent of the time in any given sector, regardless of how often the wind.blows in that direction.
The annual average X/Q is used to evaluate normal operational releases which occur continuously throughout the year. This X/Q cd be used to determine the risk of a facility or operation which includes accidents that do not necessary occur during worst-case meteorology.
The maximum X/Q for the onsite receptor for a chronic (8 hour) release using 99.5 percent meteorology is 1.48E-6 s/m3 (630 mm. The maximum X/Q for the offsite receptor for a 24 hour release is 1.19x 10-7s/m3 (12.5 km ~.
The maximum X/Q for the onsite receptor for a short term (15 minute) release using 99.5 percent meteorology is 3.85x 10< s/m3 (630 m W~
Tables 4 and 5 contain estimates of the onsite and offsite chemical concentrations based on annual average meteorology. Mso included are the appropriate concentration limits for comparison. Since water vapor is not a hdth huard, it is not included in the tables. The maximum onsite concentration based on an 8 hour release is a factor of 1.0 x 109below the TLV-TWA limit for COZ, the NOXconcentration is a factor of 1.0x 106below the limit, and there are no limits given for butene. The maximum onsite concentration based on a short term (15 rein) release is a factor of 1.0x 109below the TLV-~A limit for COZand the NOXconcentration is a factor of 1.0x 106below the limit. The maximum offsite concentration for NOXis a factor of 1.0 x 106below the ASIL limit, and there are no limits given for butene and COZ. It is therefore concluded that the health impact due to routine chemical emissions from PFP during sludge stabflimtion is negligible.
Table 4. Chetid Concentration at the Mtim Omite Receptor Locatiom Breed on 99.5 Percent Meteorolo~ and TLV-TWA/S~L Limifi.
‘ Productof maximumonsik WQ @able2) and tie ~l=se mte @able 1).
bNOXfimittiken to be N02
DOE~A-0978 B4 October 1994
_ -. —.—— ,“. .- .— U.S. Department of Energy Appendti B
Table 5. Chetid Concentrations at the M-urn Offsite Receptor Lomtions Based on Annual Average Meteorolo~ and Mm Values.
Chemiesl Conwntration ASK b (24 k) (mglm’) (mgim’~
NOX 5.0x 10’ 0.1
Butene 5.0 x 10’ NA
CarbonDioxide 1.3xl@ NA
‘ Productof maximumoffsiteWQ @able3) and the releaserate cable 1).
bA-ptable Sourcehpact bvel tim WAC 173460 WAC 1991).
1.
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DOE/EA-0978 B-5 October 1994 I U.S. Depti~ent of Energy Appendix C
Appendk C -
Cultural Resources Retiew
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DOEEA-0978 October 1994 i’
— –1 U.S. Dep~~ent of Energy Appentix C
@BaNelle Pacific Nor[hwest Laboratories Batrelle Boulevard P.O. Box999
Febnrary 3, 1993
Ms. Matilne Campbell Westinghouse Hanford Company Operations Support Services P. o. Box 1970n5-54 Richland, WA 99352 1 Dear Mardine: INSTALLATION OF MUFFLE FURNACES IN A GLOVEBOX IN PFP
In response to your request for a cuhural resources review received February 2,1994, staff at the I Hanford Cuhural Resources Laboratory (HCRL) finds that the Installation of Muffle Furnaces in a Glovebox in PFP project does not require a cuttural resources review. The HCRL staff requires a I review of all projects that are considered to be federal undert~ngs, as defined in 36 CFR Pan 800. According to the information that you supplied, PFP plans to install two muffle furnaces (small) in glovebox HC-21C to stabilize plutonium bearing sludges. Since no stmctuml modifications will occur, the proiect is not considered to be a federal undedakfn9.
Thank you for contacting the HCRL. Please call me at 372-1791 if you have any questions.
Ve~ truly yours,
M. E. Crist Concurrence: A4.A< /tiLL&LA Technical Specialist M. K. Wright, Scietit Cutiural Resources Project Cuhural Resources Proiect
cc: LB
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DOE~A-0978 c-1 October 1994 1 i —-. — — ,.. -
I U.S. Depar~ent of Energy Appentix D I
Appendti D
Tribal and Stakeholder evolvement
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I I DOE~A-0978 October 1994 I —-.—— ——..-- ,..
U.S. Department of Energy Appendix D
~bd and St*eholder evolvement
The U.S. Department of Energy and the Westinghouse Hanford Company successfully implemented a tribrd and public involvement process setting a new course for PFP activities, which include tribal and public values. In November 1993, DOE and WHC initiated small group meetings to discuss PFP activities. Meetings were held with representatives of those groups expressing a keen interest in plans for stabfltiing tie factiity. At mch meeting tiey discussed the particular concerns raised by the groups and possible options for deding with tie materials that pose worker and public safety. As the meetings occurred over a five- monti period, the discussions dso reflected ongoing correspondence between M and HQ. A new course was set which includes an Environment Impact Statement for tie PFP with interim actions to resolve safety concerns. A “wrap-up” meeting was held witi representatives of interested groups in March 1994. The destone was completed March 16, 19940
Small, informal meetings occurred with tiese groups. As these meetings were informal, transcripts were not kept.
Da& Grouu Names hcation
11/12/93 Hanford Education Lynue Stembridge, Todd Martin Spokane Action L~gue
1213193 Swtie Area Groups Gedd Po~et @cart of Amens Northwest), Tom Carpenter SeaMe (Government Awountabfity Projwt)
12/30/93 Potind Area Groups Paige fight, Bti Coti @anford Watch), Dirk Dunning Pofind (Oregon Dep-ent of Energy), BW Bires w Veterans for Pea=), Robin ~ein @anford Action of Oregon), and Dr. Richard Bekey (Oregon Physic@ for SOCMRmponsibfity)
213/94 State of Washington M CO* Depatient of Health
2/18/94 State of Washington Roger Stadey, Tom Tebb Department of Ecology 319/94 “Wrap-up”Workshop Beq Tabbutt, Josh Bdd Washington Enviromneti Councfl), Seatie LyMe Stembridge, Todd Martin @anford Edu~tion Action Lwgue), Gedd PoUet, Cynthia Sarthou @m of kenea Northwest), Greg DeBder (Columbia River United), Tom Carpenter (Govement Awountabtity Projwt), and Paige fight @anford Wa@h)
3/15/94 Confederated Tribes of Michael Farrow, J.R. Wtion, Tom Gibnore, * CMds, Mission, the UmaW hdian Les Spine, ChrisBurford Oregon Resemation
3116/94 U.S. Environmental Doug Sherwood Teleconference Protection Agency
514/94 Seatie Area Groups Tom Tebb, Pati Smith, CindyGrant, John Bkc~w, Dirk Seatie Dumdng, CynthiaSarthou,Todd M- Paige ~ght, Betty Tabbutt,Sue Gotid
DOE~A-0978 D-1 October 1994
..— ———..— I i U.S. Depa~ent of Energy Appendix E
Appendh E
Pre-Approval Retiew
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DOE~A-0978 October 1994 —- .—.. -. 1’
U.S. Dep~ment of Energy Appendix E I j
Commenti from State of Washb@on, Department of Ecolo~
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DOE~A-0978 October 1994
.— — — .— .
U.S. Depa~ent of Energy Appentix E
~ATE OF wMHIN~ON DEPARTMENT OF ECOLOGY RO. Box 4i600 ● Olympj~W~htigon98504-7600 (206)407-6000“ TDD Only (Hearing ~mptid 006) M74W6
October 7, 1994
Mr. Pafi F. X. Dunigan, Jr. U.S. Dept.. of her9Y Richland operations office PO Box 550 Ri-and WA 99352
Dear Mr. Dunigan:
On behalf OE the Depatiment of Ecology, we would like to thank you for the opportunity to comment on the environmental assessment (EA) for the Sludge Stabilizationat the Plutoniw Finishing Plant (94-TPA-147). we reviewed tie EA ~d have We following cowents.
General Assumptions Regartig the EA Approach The EA for sludge stabilizationdoes not clearly link with other Environmental Impact Statements (EISS), either planned or now underway, such that the public can see cumulative impacts and relationships among approachesto fissile materials, wastes, Hanford cleanup, transition and decommissioningof old facilities.
The EA describes $Iudge stabilization as an interim action to proceed o~er stabilization actions at the Plutonium Finishing Plant (PFP) that will be covered in a futire EIS. The rationale for excluding this interti action from this EIS lacks significant detail in the text Or graphi~ aids (e.g., chatis or graphs on personnel e~osure, costs, etc.) to convince the reader. Ecology is concerned that this material more closely res~les waste or exhibits waste-like characteristics,such that.lt should be managed as waste accordingly. The proposed alternative does not fully discuss implicationsor relationships of storage ad disposition of weapons-usablefissile material. The EA should more thoroug~y qlore the possible classificationof this material as waste and/or altering this material (spiking~ cementing, etc.) such that it is in a form not readily usable “Ybr nuclear weapons. . .
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DOE~A-0978 E-5 October 1994 !
, U.S. Dep~tment of Energy Appendix E
( I t W. Paul F. X. Dunigan October 7, 1994 Page 2
It is the Governor’s personal view that, “We have no greater I obligation in this I century than to ensure that surplus plutonium is never again used in nuclear arms -- in this nation, in the former Soviet Union, or in nations like No- Korea that covet atomic bombs.lll .
Does this material (50 lbs. of impure plutonium oxide) add additional inventory to the weapons-useable stockpile, such that it violates international treaties on nuclear arms reduction? similarly, does this material oppose the Clinton Administration’s non-proliferation initiative? To justify the preferred alternative, the EA needs additional discussion of these issues I in conte@ of the Weapons-Usable Fissile ~terial EIS that is. currently undergoing a public scoping process.
Ecology commends USDOE for providing a briefing on the stabilization of the sludge material at-PFP. ‘Ecology recognizes the efforts being made regarding public participation on sensitive materials such as plutonium and/or special nuclear materials. However, one briefing to various stakeholders, tribal nations, and regulators (USDOE briefed Ecology on February 18, 1994] that focused primarily on the process of sludge drying and . not on alternatives that include disposal options, lacks the credibility necessary far public and regulatory involvement to be successful.
We would recommend a workshop or working session that breaks down individual agendas, and puts people of diverse perspectives together as teams. The teams would focus on the viable solutions or alternatives that represent the values and perspectives of all parties. We believe that such an approach, or something similar, supports the intent of the Secretarial policy for public participation tha: provides respect for different perspectives, and a genuine west for a diversity of information and ideas.
safety ana Environmental concerns and Assumptions
Section 2.2 Process Description
●✎✎ This section describes how the process of drying the sludge will occur and where. From reading this section, apparently 400 tD 600 batches would need to be processed, though the estimated number of containers. containing less than 2 percent organic
1 Commauof Governor Mbb~ on tie Storage andDk~ition ofWeapo&U*le F~stie I Matti&DeUmred byDonWolgarnow DepugS@DireUor, Au~t3L~.
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DOE~A-0978 E-6 October 1994
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U.S. Depatrnent of Energy Appendix E
I
Mr. Paul F. X. Dunigan October 7, 1994 Page 3
composition is not given. This appears to be a lot of han-~ing. HOW have plant personnel been trained to accomplish this without incident? Please describe in more detail.
Section 5.4.1 Accident Scenario
This section discusses the potential accident scenario related to flammable gas (i.e., but~e) defla~ation= Additional d+sassion is needed on operational readiness review related to hav~ng the e~ipment perform as it would if operational. The results of such reviews would lend credibility to the probability percentage (0.00001) of an accident occurring.
The EA indicates that butene in the furnace offgas will not reach its lower flyability limit (LFL). As most offgas systems are designed to use below the 25 percent of the LFL, allowing a level below, but near, the LFL may not be ade~te.
Permits =d Regulatory Re~irements
Ecology also notes that A Notice of.Construction air permit is rewired for the two new muffle furnaces and was not clearly addressed (page 6-l).
Alteaative Options
The disposal alternative has not been thoroughly e~lored or explained in sufficient detail to exclude it as a viable ‘1 alternative. The worker radiation exposure is less than the proposed alternative, and has the attractiveness of I dispositioning the plutonium in fom from which the plutonium would be diffictit to recover. I The ~ should prdvide more detail -out why 250 drums would occupy 60 percent of the capacity of the Cent=l Waste Compl=. Is the capacity problem related to curie content or volme of drums? I The 250 drums would use only 12.5 percent of the Transuranic Waste Storage and Assay Facility’s capacity. Which USDOE directives do not allow this amount and classification of special nuclear material to be stored at TRUSAF? Please provide a reference or citation documenting this statement.
We recommend that a working group be established with a strategy for reviews to more clearly reflect the concerns of the state of Washington on this impotiant issue.
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DOE~A-0978 E-7 October 1994 U.S. Depa~ent of Energy Appendix E
. . W. Paul F. X. Dunigan October 7, 1994 Page 4
If you have any ~estions, please call W. Ron Effland with our Nuclear Waste Program at (206] 407-7134.
Keith E. Phillips? Supervi&or Environmental Review and Sediment Section
KEP :Vs 94-7376
cc: Ran Effl~d, ~ Bob King, ~ . G. Thomas Tebb, Kennewick
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I DOE~A-0978 E-8 October 1994
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I I U.S. Depw~ent of Energy Appendix E
I , f
Department of Energ Response to Commenti from State of Washh@on, Department of Ecolo~ i
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I DOE~A-0978 October 1994 .— -—...— .
! U.S. Depatsnent of Energy Appendix E
‘a Department of Energy Richland Operations Office P.o. Box 550 . 0w Richland, Washington 99352 95-TPA-016
Mr. Keith E. Phillips,Supervisor, EnvironmentalReview and SedimentSection State of Washington Department of EcologY P.O. BOX 47600 Olympia, Washington 98504-7600
DearMr. Phillips:
RESPONSE TO STATE OF WASHINGTONDEPARTMENTOF ECOLOGY COMMENTS ON THE ENVIRONMENTALASSESSMENT FOR PLUTONIUMFINISHINGPLANT SLUDGE STABILIZATION i Thank you for your comments on the EnvironmentalAssessment for Sludge Stabilizationat the PlutoniumFinishingPlant.
Mr. 0. A. Farabee, acting directorof the U.S. Departmentof Energy, Richland .OperationsOffice, TransitionProgramDivision,met with Mr. G. T.afibb of the State of Washington Departmentof Ecology,Nuclear Waste Program, Mr. D. J. McBride of the WestinghouseHanford Company Plutonium Finishing Plant on October 13, 1994, to discuss the comments. The enclosed responses to your comments reflect the discussion. Please refer any questions to me on I (509} 376-6667, or Mr. B. F. Burton on (509) 373-3341. i ‘/ Sincerely, I ,
. Paul F. X. Dunigan,Jr. I NEPA ComplianceOfficer \ Enclosure [ cc w/encl: R. Effl.and,Ecology G. Tebb, Ecology G. Tallent, Ecology
I I I DOE~A-0978 E-11 October 1994 1 ——-——J U.S. Dep~~ent of Energy Appendix E
RESPONSE TO COMMENTS ON THE EWIRONMENTAL ASSESSMENT FOR PLUTONIUM FIMSH~G PLANT SLUDGE STABILIZATION
1. me U for sludge stabilizationdoes not clearly link with other Environmental Impact Statements @ISs), eitherplanned or now undemay, such that the public can see cumulative impacts and relatiomhips among approachestofissile wteriah, wmtes, Hanford cleanup, transition and decommissioningof old facilities.
Response: The proposed action does not affect or prejudice decisions being considered in other Environment Assessments (EAs) or Environment Impact S@tements (EISS) currentiy in preparation. The material being stabilized is simply being placed in a safer cotilguration pending a policy decision on the ultimate disposition of the material.
There are, however, several ongoing National Environment Policy Act ~PA) reviews which wdl affect activities at the Plutonium Finishing Plant (PFP) and the ultimate disposition of the plutonium stored at the PFP (including the sludge items). The most relevant documents and their anticipated impacts include:
Programmatic Environment Impact Stitement for Storage and Disposition of Weauons-Usable Fissile Materials @EIS) -- This NEPA review, which was initiated after the preparation of the Sludge Stabtiization EA and therefore is not included as a reference, wtil determine ti-e ultimate disposition of plutonium and other special nuclear materials currently stored throughout the DOE Complex. It wtil therefore affect activities at the PFP and the find disposition of the sludge items discussed in the EA. Untfl the PEIS is complete, it is important to avoid i -g actions which may prejudice or contradict the decisions under evaluation.
Plutonium Finishing Plant Cleanout Environment ImDact Statement PFP ~ --me S1udge Stibfltition EA describes an interim action to precede the PFP EIS. The PFP EIS wtil evaluate impacts and alternatives for stabilization of plutonium-bearing materials within the PFP; cumulative impacts from completed interim actions wfll dso be included.
Environment Assessment:Shutdown oftheFastFluxTestFacilitv. HanfordSite,Washington-The EA forshutdownoftheFFTF describesthe stepsnecessaryfortransitionand shutdownoftheFFTF toa statereadyfor decommissioning.One activityincludedintheEA is the transfer of unirradiated fuel from the FFTF to the PFP for storage. Whfle this activity affects the PFP, it does not affect the storage locations used for sludge items either before or after they are stabilized.
DOE~A-0978 E-12 October 1994 I .——..——— ,-
U.S. Dep~tient of Energy Appendix E
2. me ~ describes sltige stabilizationas an interim action to proceed [sic] other stabilization actions at the PlutoniumFinishingPlant ~FP) that will be covered in a@ture EIS. me rationalefor acltiing this inten.mactionfrom this EIS
lath signl~cant detail in the t&or graphical aids (e.g., charts or graphs on I personnel aposure, costs, etc.) to convincethe reader.
Response: Section 1.0 of the EA includes a dticription of the worker safety just~lcation for promptiy stabtiizing chemically reactive plutonium-bearing materials currentiy stored in gloveboxes within the Plutonium Ffihing Plant. Section 5.2 elaborates I on the expected dose reduction from the actio~ a projected reduction of 4 rem per year is expected after completion of the stibfitition activity.
3. Ecology is concernedthat this material more closely resembleswaste or ahibits waste-like characteristics,such that it shouti be manageda a wme accordingly. me proposed alternativedoes notfilly discuss implic~.om or relationshipsof storage and disposition of weapons-wablefissile material. me U shouu more thoroughly aplore the possible classl~cationof this mterial as wtie and/or altering this material (spiking, cementing, etc.) such that it is in aform not redily usablefor nuclear weapons.
Response: It is the policy of the Department of Energy that plutonium and other fiisfle materials currentiy in storage within the Plutonium Finishing Plant should be considered to be special nuclear material rather than waste untfi such time as a national policy decision on the ultimate disposition of the material can be reached.
As discussed in the response to comment #1, the Programmatic Environment Impact Statement for Storage and Disposition of Weapons- Usable Fisstie Materials wfil addrws the ultimate disposition of the plutonium in storage. Untfl a disposition decision is reached, it is premature to attempt to further adulterate or alter the materird in a manner which may be incompatible with ifi ultimate disposition. me stabilization activity proposed in the EA is intended to make the materials safe for intermediate storage pending a disposition decision, without purifiing the materials or making them more readfiy usable in weapons.
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DOE/EA-0978 E-13 October 1994 I I U.S. Depz~ent of Energy Appendix E
I 4. It is the Governor’spersonal vim that, “Wehave no greater obligation in this I centu~ than to ensure that suplus plutonium is never again used in nuclear arms -- in this nation, in thefomer Soviet Union, or in nations like North Korea that I covet atomic bombs.” { Response: ,$ The Department of Energy believes that the sludge sbbfiization activity is 1 consistent with the Governor’s viewpoint.
I 5. Does this wterial (50 lbs. of impureplutonium oxide) tid tiditional invento~ to
●-. the weapom-usable stoc@ile, such that it violates internationaltreaties on .i nuclear arms reduction?
Response: The reactive sludge items described in the EA are aheady in existence and are identified in plutonium inventories as residue materials. The reactive sludge items contain impurities which would prevent their use I direcfly in weapons production without further processing. In addition to the .i impurities, the sludge items contiin moisture and trace organics which cause the materials to generate gases and prevent their placement in sealed storage in vaults. The sludge stabilization activity described in the EA would drive I off the moisture and trace organic components to enable safe storage, but would not purify the materials or m~e them more suitible for weapons production.
It should be noted that although the materials are not considered suitible for weapons use without tither processing, they do fit the definition of I weapons-usable f~stie materials in the context of the Programmatic Environment Impact Stitement for Storage and Disposition of Weapons- Usable Fissfle Materials, and may therefore be included in the decision on the ultimate disposition of these materials. I ! 5a. Similarly, does this material oppose the ClintonAdministration’snon-proliferation ,1 initiative? Tojush~ the pr~erred alternative, the EA needs additional discussion ,[ of these issues in contti of the Weapons-UsableFissile Maten”alEIS that is I currently undergoinga public scopingprocess.
Response: Please see the response to item #5 above. The proposed action under the EA will not lead to the export of special nuclear materials or technology, and is therefore consistent with the Admtitration’s policy.
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DOEEA-0978 E-14 October 1994
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U.S. Depm~ent of Energy Appendix E
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6. Ecology commends USDOEfor providing a bri@ng on the stabilization of the sltige material at PFP. Ecology recognizesthe @orts being Me regarding public participation on sensitive mteriak such as plutonium and/or special nuclear rnateriah. However, one bn.efingto van.ousstakehotiers, tribal nations, and regulators (USDOEbri~ed Ecology on February 18, 1994) thatfocused I primarily on the process of sludge d~ing and not on the alternativesthat included 1 disposal options, lacti the credibili~ necessaryfor public and regulatory I involvementto be succes@l. I I Response: A series of briefings and workshops were conducted with stieholder, tribal, and regulatory agencies starting in November, 1993, and continuing through the present. These briefings have addressed comments and suggestions from several parties regarding sludge stabfibtion vs. disposd options, and serious consideration has been given to disposd dternativm. (See response to item #12.)
As part of the public participation efforts related to the sludge stabtiization activity, a preliminary draft of the EA was made avadable to the State, Tribes, and stakeholder groups in May, 1994. On May 4, 1994, in a stakeholder briefing, copies were hand-delivered to representatives of the Washington Department of Ecology (G. T. Tebb and Paula Smith), Washington Department of Health (Cindy Grant and John BlacNaw), Oregon Department of Energy (Dirk Dunning), Heart of America Northwest (Cynthia Sarthou), Hanford Education Action hague ~odd Martin), Hanford Watch @aige fight), Washington Environment Councfl @etty Tabbutt), and the Hanford Advisory Board (Sue Gould). Additiond copi~ were mafled during the fo~owing week to tribal representatives and to interested parties who did not attend the briefing.
The o~y written commenk received on the preliminary draft EA were horn the Washington Department of Health. Ord comments were received from several interested parties and were incorporated into the EA also. The Washington Department of Ecology did not make any comment at that the.
7. We WOUHrecommeti a worhhop or working session that breah down itiividual agendas, ati puts people of diverseperspem.ves together as teams. me teams wouti focus on the viable solutions or alternativesthat represent the values ad perspectives of all parties. We believe that such an approach, or something similar, suppotis the intent of the Secretarialpolicy for public pa~.cipation that provides respectfor dl~erentperspectives, ad a genuine questfor a diversi~ of informationand ideas.
DOE~A-0978 E-15 October 1994 I U.S. Depatient of Energy Appendix E
Response: As discussed in item #6 above, the public involvement workshops held to date have led to extensive opportunities to share viewpoints and suggestions for viable alternatives.
I Safety and Envkonrnentd Concern and &mptions .! 8. (Section2.2 ProcessDescription) -- ~is section describes how the process of drying the sludge will occur and where. From reading this section, apparently
‘ 400 to 600 batches WOUUneed to be processed, though the estimated number of “1 containers containingless than 2 percent organic compositionis not given. ~is appears to be a lot of handling. How have plant personnel been trained to accomplishthis without incident? Please describe in more detail.
Response: Nuclear process operators at the PFP are extensively trained in operations involving the handling of plutonium; the PFP’s primary mission since its startup I in 1949 has been the safe handling, processing, and storage of plutonium-bearing materials.
In addition to this broad base of experience and training, specific training packages were developed for the operation of the sludge stabilization process. The operator trafig consisted of both classroom training and on- the-job training. The classroom training assured that the operators understand the hazards and participles behind sludge stabilization. The on- the-job training involved having the operators actually operate the equipment without plutonium-bearing feed. Drflls were prepared and run to assure the operators could rmpond to upset conditions.
I 9. (Section5.4.1 Accident Scenario)-- ~is sea”ondiscwses the potential accident scenario related toflammble gas (i.e., butane [sic]) d@agration. Additional discussion is needed on operationalreadinessreview related to having the equipmentpeflorm as it wouti lf operational. me results of such reviews WOUU 1 lend credibility to the probabilitypercentage (0.00001)of an accident occurring.
I Response: The safety ~ysis in the EA assumes a faflure of four safety barriers which assure worker safety from a butane deflagration (see response to item #10 below). The probability of occurrence described in the EA includes a factor to account for the fatiure potential of the equipment. The operation of the equipment is motitored continually by operators and functiotily tested annurdly by trained I and certified technicians. ,
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I I I DOE~A-0978 E-16 October 1994 I I I i __ .— - . _.. .- -.. -.— . . .,---- ..-..------. , ,.,-.———— —-—-——- , ; - —-— -- - , ,. >,, , : ...... :- —..
U.S. Depar~ent of Energy Appendix E
The readiness assessment was performed by a board of personnel that included both Safety and Quality Assurance personnel. The board assured that dl equipment was instiled and functioning properly. The board dso assured thatdl documentation was in place and dl operator training had been completed. me assessment was overviewed by DOE-HQ, DOE-RL, and WCTEC (an independent contractor): The Defense Nuclear Facilities Safety Board (DNFSB) dso performed an independent review of the preparations.
10. me U indicates that butane in thefimace oflgm will not reach its lower flammabilip limit @FL). As most ofgas systems are designed to use below the 25 percent of the LFL, allowing a l~el below, but= the LFL ~ not be adequate.
Response: Under normrd conditions, levels of butane in the tinace offgas are projected to remain below 15% of the Lower Flammability hvel (LFL) ~C-SD-CP-OCD- 040, Rev. O-A, “Basis Document for Sludge Stabflimtion”). There are four safety barriers thatare inplace toassureworker safety from a deflagration of a flammable gas @utane). hss of any single barrier wfll not make the system unsafe. The four barriers are 1) sampling materials to be processed for tributyl phosphate VBP, which generates butane when heated) and limiting the TBP to 10 grams; 2) holding the temperature below the flammability point (250°C) untfi dl TBP has reacted; 3) providing a carbon dioxide purge to thefinace to dflute any butane generated; and 4) using an exhaust system to remove gases so they do not build up in the furnace. The combination of these safety barriers are designed to insurethebutane concentrationsstaybelow 25% of the LFL.
Ped6 and Regdatory Reqtiemenfi
11. Ecology ako notes that A Notice of Constructionair permit is requiredfor the two new m~efimaces and was not clearly addressed @age6-1).
a on Response: In meeting with Washington Department—of Health personnel June 12, 1994, it was determined thata Notice of Construction is not required for this project because it does not constitute a new activity at the facfli~. The facflity has operated a simflarprocess using sludge stabflimtion tinaces in the past.
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DOE/EA-0978 E-17 October 1994
.- U.S.Depatrnent of Energy Appendix E
I Alternative Options
12. me disposal alternativehas not been thoroughlyaplored or aplained in s@cient detail to ~cltie it as a viable alternative. me worker rtiiation I aposure is less than theproposed alternative, and has the attractivenessof 1 dispositioningthe plutonium in afomfiom which the plutonium would be dl~cult to recover.
Respome: The quantity and attractiveness categorization of tie materials is such that in accordance with DOE Order 5633.3A, “Control and Accountabtiity of Nuclear Materials,” the sludge items are considered to be a Category II quantity of Attractiveness bvel D material. This type of material requires safeguards to prevent unauthorized diversion or theft. In accordance with tie referenced order, this category of material is dso not eligible for disposition as waste unless a vulnerability assessment demonstrates that there is not a risk of diversion or theft.
There are several additioti factors which make the disposd of the reactive sludge items unattractive. As discussed in tie response to item #3, it would be premature totreat the materirds in a manner which may be inconsistent with their ultimate disposition. The items would dso uttiize an substantialportion of the avatiable waste storage capacity onsite.
I It should be noted that serious consideration has been given to the disposal ! I alternative. An evaluation of the sludge items was performed to determine whether some of the items could meet disposd criteria. In May of 1994, thirty- I three items containing a minimal amount of plutonium, which were initially proposed for thermal stabilization, were determined to be discardable under \ existing policies and procedures. These items were cemented and sent to 20-year
1 I retrievable storage for eventu~ disposition in the Waste Isolation Pfiot Plant. I ‘1 13. me U shouti provide mre detail about why 250 drums WOUHoccupy 60 percent of the capacity of the Central Wrote‘Compla. Is the capaci~”problem related to curie content or volume of drums? I I Response:
I As discussed in the EA, section 3.2, the Central Waste Complex capacity is I limited based on the curie content of the drums. , ( I
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14. me 250 drums WOUHuse only 12.5 percent of the TransuranicW&e Storage and ksay Facilip ’s capacity. ~ich USDOEdirectives do not allow this amount and classl~cationof special nuclear material to be stored at ~UW? Please provide a reference or citation documentingthis statement.
Response: See response toitems#12 and #13 above.
15. We recommendthat a worting group be establishedwith a strategyfor reviews to more clearly r@ect the concerns of the State of Washingtonon this important issue.
Response: Refer to item #6 for a discussion of workhops and briefings held to date.
I For the purposes of the stabilization of reactive plutonium-bearing sludge items at the PFP, it is the DOE’s position that the extensive public and regulatory participation proc~s which was used to help develop the Sludge Stabilization EA hm been r~ponsive in addrmsing tie stated concerns of stieholder, regulatory, and tribal interwts.
It is apparent that continued and increased participation by the regulatory agencies and other interested parties wdl be beneficial in achieving the DOE’s gods of stabilizing the process areas within the PFP and determining the ultimate disposition of plutonium items stored throughout the DOE Complex. Opportunities for this interaction wU1 include scoping meetings for both the PFP EIS and the PEIS, as well as briefings and worhhop sessions as needed.
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DOE~A-0978 E-19 October 1994 .__-. —— .—-
FINDING OF NOSIGNIFICANTIMPACT
FORSLUDGESTABILIZATIONAT THE
PLUTONIUMFINISHINGPLANT
HANFORDSITE, RICHLAND,WASHINGTON
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AGENCY: U.S. Department of Energy
ACTION: Finding of No Significant Impact
SUMMARY: The U.S. Department of Energy (DOE) has prepared an environmental
assessment (EA) DOE/EA-0978 to assess potential environmental impacts from
sludge stabilization at the Plutonium Finishing Plant on the Hanford Site.
Alternatives considered in the review process were: the No Action I
alternative; discarding the sludge as waste and placing it in drum storage
for future disposal; processing the material more extensively using the
historic purifying production type processing or vitrification for long-term
isolation; and the preferred alternative of drying the sludges in muffle
furnaces and storage of the dried sludge in PFP vaults. Based on the analysis
in the EA, and considering proapproval comments from the State of Washington
and the Confederated Tribes of the Umatilla Indian Reservation, DOE has
determined that the proposed action is not a major Federal action
significantly affecting the quality of the human environment within the
meaning of the National Environmental Policy Act of lg6g (42 U.S.C. 4321 ~
M“)” Therefore, the preparation of an Environmental Impact Statement (EIS)
is not required.
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ADDRESSES AND FURTHER INFORMATION:
Single copies of the EA and further information about the proposed action are available from:
Mr. O. A. Farabee, Acting Director Transition Programs Division U.S. Department of Energy t Richland Operations Office P. O. Box550 I Richland WA99352 I Phone: (509) 376-8089
For further information regarding the DOE NEPA process, contact:
Ms. Carol M. Borqstrom, Director Office of NEPA O~ersight U.S. Department of Energy I 1000 IndependenceAvenue, S.W Washington, D.C. 20585 Phone: (202) 586-4600 or (800 472-2756
PURPOSEANDNEED: DOE needs to reduce worker exposure to radiation from plutoniurnS1udges stored at the PFP. Currently, PFP workers account for nearly half of all Hanford Site radiation exposure to workers.
BACKGROUND: The PFP began operations in 1949 to convert plutonium nitrate solutions into plutonium metal. This activity continued through 1988. The sludges are residues remaining from these production processing operations. The sludges contain approximately 25 kilograms (55 pounds) of plutonium along with other chemicals in a slurry with high moisture content.
The action to reduce the worker exposure by stabilizing the sludges in the gloveboxes is an interim action (consistentwith 40 CFR 1506.1) pending completion of an environmental impact statement (EIS) concerning the proposed cleanout and stabilization of the remaining reactive materials within the PFP. This action will not limit the choice of reasonable alternatives or prejudice the Record of Decision for that EIS.
PROPOSEDACTION: The proposed action is to stabilize the chemically reactive plutonium-bearingsludges within the process gloveboxes in the PFP, and store f the stabilized sludges in shielded storage vaults in the PFP.
The sludges would be stabilized by heating the sludges to approximately 500° to 1000°C (900 to 1800°F) and converting thereto plutonium oxide (Pu02). The other chemicals not driven off by the heat would remain as stable impurities in the resulting solid. The solid PU02 would be stored in sealed containers in the vaults at PFP. There are approximately300 containers of reactive scrap sludges which require stabilization. These contain a total of 25 kilograms (55 pounds) of plutonium. — {I I The process will use two 4000-watt laboratory-sizemuffle furnaces installed I in glovebox HC-21C located in room 230A of building 234-5Z within the PFP. Sludge stabilization is expected to take about 14 months. , 1 ALTERNATIVESTO THEPROPOSEDACTION: I I No Action: The No-Action Alternative consists of not stabilizing the plutonium bearing material at this time. The material would continue to be stored in the process gloveboxes. The workers would continue to receive radiation doses during required glovebox operations. The PFP workers would continue to receive approximately4 person-rem per year from storage of the sludge, and the glovebox space would not be made available for future cleanout. No Action does not meet the need for agency action. I Disposal Alternative: Another alternativewould be to dispose of the material as a waste before a final decision has been made regarding the ultimate disposition of the material. Disposal of fissile materials is not allowable under DOE Order 5633.3A, Control and Accountabilityof Nuclear Materials. However, if allowable, the most likely disposal process for these solid sludges would be to cement the solids in a form that meets Waste Isolation Pilot Plant (WIPP) disposal criteria. The process would involve diluting the I materials, mixing them with a concrete material, then pouring the mixture into I I 0.5-liter (l-pint) containers. The containers would be packaged in 208-liter (55-gal1on) drums for storage.
The 250 drums required to contain the cemented material would be stored on the Hanford Site pending future decisions on waste disposal. Because of its high curie content, the waste would use approximately60 percent of the total waste storage curie capacity within the Central Waste Complex. The 224-T Transuranic Waste Storage and Assay Facility (TRUSAF),which does not have a curie limit, has sufficient space to accept the drums. This alternative, if it were allowable, would use a large amount of the existing storage space in either the 224-T TRUSAF or the Central Waste Complex.
Processing Alternative: Several processing alternativeswere considered that could stabilize the sludge. These include operating the Plutonium Reclamation Facility or vitrifying the sludges. Some of these alternatives are technically viable however, they are more expensive than the proposed action, are similar to past defense production processing, may make the stabilized material more difficult to work with in the future, and would expose the operating staff to substantially higher doses of radiation. The sludges would still need constant handling with continued worker exposure while the process is developed and prepared. Therefore the processing alternatives do not meet the need for agency action.
Offsite Treatment and Storaqe of Sludqes Alternative: An alternative that would meet the need for the proposed action would involve transporting the sludges to an offsite facility for treatment and disposal. However, existing regulations prohibit offsite transport of unstabilized fissile materials. Also the transportation of this material on public roads would require packaging not yet developed to meet transportationrequirements (49 CFR 173.416 and 173.417). Accordingly, this alternativewas dismissed from further consideration. +------
ENVIRONMENTALIMPACTS:
Operational Impacts: Routine sludge stabilization operations would result in small airborne chemical or radioactive emissions, indistinguishable from historic releases from PFP. Impacts from these emissions are expected to be 1 extremely small. For example, in 1983, PFP contributed a collective dose of I 0.0367 person-rem to the offsite public. This dose would be expected to I result in about 0.000018 cancer fatalities among members of the public (i.e., no cancer fatalities). The proposed action would result in a reduction of approximately 4 person-rem per year for all PFP operators. However, the proposed action would result in radiation exposure to the workers when they perform operations involving close proximity to the sludges. The cumulative dose to the workers would be 17 person-rem for the duration of the stabilization action. This would result in an estimated health effect of approximately 0.007 cancer fatalities for the directly exposed workers. Radiation exposure to each operations worker is limited to no more than 2.0 rem per year, with administrativedose controls and an individual monitoring program which provides hold points starting at a cumulative exposure to any worker of 0.5 rem.
Sludge stabilizationwould generate a small amount of radioactive solid waste. The volume of waste is estimated to be 0.01 cubic meter (0.5 cubic foot) per day. This waste represents a small incremental increase in the total amount of waste generated daily at the Hanford Site. The waste would be stored or disposed at the Hanford Central Waste Complex.
Socioeconomic Impacts: The proposed action would be performed by the existing workforce. Therefore no socioeconomic impact is expected.
Cumulative Impacts: The proposed sludge stabilizationat PFP would not have a substantial cumulative effect when considered with other activities on the Hanford Site. The incremental impact of the emissions from the sludge stabilization would be very small.
Potential Accidents: Two potential accidents were analyzed for the sludge stabilization process: a major fire in the glovebox and a flammable gas deflagration. Both accidents have a probability of occurrence of 1 x 10-5or I less. The estimated probability for either accident leading to a release of radioactive materials is the same, and the consequences from the flammable gas accident would be slightly higher; therefore, this was evaluated as the bounding accident. Flammable gas (i.e., butene) would be generated during sludge stabilization operations due to the presence of tributyl phosphate (TBP) in certain feedstocks. It is assumed that twice the control level of TBP is present, the normal inert covergas is absent, the furnace offgas system is blocked, and the controller fails in such a manner that all of butene potentially available is evolved instantaneously. The butene is assumed to form a flammable mixture in the glovebox and ignite. The resultant deflagration is conservatively assumed to breach the glovebox releasing material into the surrounding room, and releasing 0.048 grams (0.0001 pounds) of plutonium from the PFP stack. The committed effective dose equivalent for I this potential accident would be 3.58 person-rem (0.0015 latent cancer fatalities) for the PFP workers and 21.5 person-rem (0.011 latent cancer fatalities) for the offsite public. It is most likely that none of the accidents analyzed would produce any cancer fatalities. DHEWINATION: Based on the analysis in the EA, and after considering the proapproval comments of the State of Washington and the Confederated Tribes of I the Umati?la Indian Reservation, I conclude that the proposed sludge stabilization does not constitute a row-orFederal action significantly affecting the quality of the human environment within the meaning of NEPA. I Therefore, an EIS for the proposed action is not required.
Issued at Richland, Washington, this /y~day of October, 1994.
Manager - / Richland Operations Office
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EA/FONSI DISTWBUTION LIST DOE/EA-0978 PAGE 1 OF 5 ,,
Number of Receiving Receiving Organization’s Address Comments Copies Orgmization
6 EH-25 C. M. Bergstrom, Director Include a copy of the EA Office of NEPA Oversight distribution list in the 1000 Independence Avenue S.W. EA/FONSI package. Washington, D.C. 20585 1 EM-64 E. G. Feldt, NEPAPoint of Contact 1000 Independence Avenue S.W. Washington, D.C. 20585 Attention: EM-64 1 EM-64 Rick Martinez, NEPA Point of Contact 1000 Independence Avenue S.W. Washington, D.C. 20585 Attention: EM-64 . 1 EM-22 M. H. Meinrock, NEPA Point of Contact 1000 Independence Ave. S.W. Washington, D.C. 20585 Attention: EM-22 1 EM-60 NEPA Point of Contact 1000 Independence Avenue S.W. Washington, D.C. 20585 .. Attention: EM-60 1 RL K. K. Randolph Communications MSIN: A7-75 1 RL S. J. Zaro Communications MSIN: A7-75 1 RL L. D. Romine MSIN: R3-79 1 RL P. F. X. Dunigan, Jr. Include a copy of the EA NEPA Compliance Officer distribution list in the MSIN: ‘A5-15 EAEONSI package.
10 RL B. Burton Include a copy of the EA DOE distribution fi;t in the MSIN: T4-18 EA/FONSI package.
For additiond copies of this EA, please contact R. H. Engelmann, Westinghouse Hanford Company, P.O. Box 1970, MSIN: H6-26, Richland, Washington 99352 (509) 376-7485. EA/FONSI DISTRIBU~ON LIST DOE/EA-0978 PAGE 2 OF 5
5 RL J. D. Wagoner Manager MSIN: A7-50 1 MACTEC D. J. Guzzema MACTEC MSIN: B142 1 MACTEC R. A. Kropp MACTEC MSIN: S6-81 1 WHC Environmental Resource Center MSIN: H6-07 1 WHC R. H. Engelmann, Manager Insert EA/FONSI package NEPA Services organtiation into tie Organkation’s MSIN: H6-26 reference file. 1 WHC C. H. Eccleston, Author NEPA Services organbation MSIN: H6-26 1 WHC Mr. D. J. McBride MSIN: T5-54 1 WHC Mr. E. C. Vogt MSIN: Tj-jO 1 WHC Mr. P. R. Prevo MSIN: NI-72 ~ 1 WHC Ms. E. V. Weiss MSIN: T3-01 1 WHC B. B. Nelson-Maki MSIN: T3-01 1 WHC S. E. Knaus NEPA Services organkation MSIN: H6-26 1 WHC T. E. Huber MSIN: T3-01 1 PNL P. M. Daling MSIN: K8-07
For additiond copies of this EA, please contact R. H. Enge]mann, Westinghouse Hanford Company, P,O. Box 1970, hISIN: H6-26, Richland, Washington 99352 (509) 376-7485. EA/FONSI DISTRIBUTION LIST DOE/EA-0978 PAGE 3 OF 5
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1 PNL Hanford Technical Library 3760 Building 300 Area -MSIN: P8-55 Richland, Washington 99352
1 HEAL Mr. James Thomas, Research Director Hanford Education Action League 1720 N. Ash Spokane, Washington 99205
1 EPA Karen Prater U.S. En\’ironnlental Protection Agency 1200 6th Avenue, HW-070 Seattle, Washington 98101
1 HOA Mr. Gerrdd Pellet 1305 Fourth Avenue Cobb Building, Suite 208 Seattle, Washington 98101
1 GAP Mr. Thomas E. Carpenter, Director Governrnent Accountability Project 1402 Third Ave., Suite 1215 Seattle, Washington 98101
1 Columbia River Mr. Gregory DeBruler, Technical Consultant United Columbia River United P.O. Box 912 Bingen, Washington 98605 ., ~ 1 Hanford Watch Ms. Paige Knight Hanford Watch 2285 SE Cypress Portland, Oregon 97214
1 Public Dr. Richard Belsey Oregon Physicians for Social Responsibility 030 SW Ridge Dri\’e Portland, Oregon 97219-6566 1 Public DOE Public Reading Room WSU Tri-Cities Branch MSIN: H2-53 Richland, Washington 99352
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For additional copies of this EA, please contact R. H. Engelmann, Westinghouse Hanford Company, P.O. Box 1970, MSIN: H6-26, Richland, Washington 99352 (509) 376-7485. -—— —
EAEONSI DISTWBUTION LIST DOE/EA-0978 P.4GE 4 OF 5
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1 Public EIeanor Chase University of Washin~on Suzzdlo Library Government Publications Room Mail Stop FhI-25 Seattle, \Vashington 98195 1 Public Joyce Cox Gonzaga University Foley Center E. 502 Boone Spokane, Washington 99258
1 Public Michael Bo\vman Portland State University Branford Price hlillar Library Science and Engineering Park Portland, Oregon 97207 1 Public Ms. Judy Mchfakin, Head Librarian Richland Public Library 955 Northgate Drive Richland, Washington 99352 1 ODOE Mr. Ken Niles Oregon Department of Ener=q - 625 Marion Street NE Salem, Oregon 97310 . . . 1 ODOE Mr. Dirk Dunning Oregon Department of Energy 625 Marion Street NE Salem, Oregon 97310 1 EcoIog NEPA Coordinator , Environmental Revie\v Section State of Washington Department of Ecolog P.O. Box 47703 Olympia, }Vashington 98504-7703
For additiond copies of this EA, please contact R. H. Engelmann, Westinghouse Hanford Company, P.O. Box 1970, MSIN: H6-26, Richland, \Vashington 99352 (509) 376-7485.
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EAEONSI DISTNBUTION LIST DOE/EA-0978 PAGE 5 OF 5
1 Ecology Marilyn Smith State of Washington Department of Ecology Nuclear and Mixed Waste Library 300 Desmond Drive Lacey, Washington 98503 1 Nez Perce Tribe Ms. D. Po!vauk= Nez Perce Tribe P.O. BOX 365 Lap]vai, Idaho 83540 1 Umatilla Tribe Mr. J. R. Wilkinson Confederated Tribes of the Umatilla Reservation P.O. BOX 638 Pendleton, Oregon 97801 b 1 Umatilla Tribe Mr. William H. Burke, Chair Tribrd Emergency Response Committee Treasurer, Board of Trustees Confderatd Tribes of tie Umatilla Indian Reservation P.O. BOX 638 Pendleton, Oregon 97801 1 Wanapum Indian Tribe Mr. Richard Buck, Jr.
, Wanapum Indian Bmd P.O. BOX 878 Ephrata, Washington 98823 . . 1 Yakama Indian Nation Mr. Russell Jim Yakama Indian Nation P.O. Box 151 Toppenish, Washington 98948
For additional copies of this EA, please contact R. H. Enge]mann, Westinghouse Hanford Company, P.O. Box 1970, MSIN: H6-26, Richland, Washington 99352 (509) 376-7485. 1 .
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